RegImpact
ftcproposed· Published 12/5/2025

Agency Information Collection Activities; Proposed Collection; Comment Request; Extension

The Federal Trade Commission ("FTC" or "Commission") is seeking public comment on its proposal to extend for an additional three years the current Paperwork Reduction Act ("PRA") clearance for information collection requirements in its "Used Motor Vehicle Trade Regulation Rule" ("Used Car Rule" or "Rule"), which applies to used vehicle dealers. That clearance expires on February 28, 2026.

What this rule actually says

The FTC is asking for permission to keep collecting paperwork from used car dealers for the next three years. This is purely administrative—the FTC is renewing its ability to gather information from car lots to make sure they're following disclosure rules about vehicle history, odometer readings, and defects. This has nothing to do with AI.

Who it applies to

  • If building an AI medical scribe: Does not apply.
  • If building a hiring assistant: Does not apply.
  • If building a support chatbot: Does not apply.
  • If selling used cars and using AI to manage inventory disclosures: Possibly applies, but only the paperwork-handling part, not the AI itself.
  • Jurisdiction: US only.
  • Data scope: Only applies to information the FTC collects from dealers about compliance—not about your users or customers.

What founders need to do

Realistically, nothing. This regulation is about the FTC's internal administrative process for collecting compliance reports from used car dealerships. It doesn't create new rules, impose new requirements on businesses, or restrict AI use. The FTC is simply renewing a form collection clearance that's about to expire.

If you happen to run a used car dealership that uses AI, you're already required to disclose material facts about vehicles to buyers—that's the existing Used Car Rule. AI doesn't change that obligation. But this specific proposal doesn't tighten those rules or introduce AI-specific compliance work.

  1. Check if you sell used cars (1 minute): If not, stop here.
  2. If you do: Review your current vehicle disclosure practices (already ongoing). Nothing changes December 5, 2025.
  3. Optional monitoring (5 minutes): The FTC might propose *changes* to the Used Car Rule itself in the future—those would matter. Bookmark the FTC's Used Car Rule page if you're in that space.

Bottom line

Ignore this unless you're a used car dealer, in which case monitor it but don't panic.