What does California SB 766 require auto dealers to archive?

California SB 766 (the CARS Act) requires every auto dealer advertising to California consumers to retain internet-based vehicle advertisements for two years. This includes vehicle detail pages (VDPs), total price disclosures, financing terms, payment calculators, promotional modals, expandable disclosures, and any other dynamically rendered content visible to the consumer. The statute takes effect 1 October 2026.

Does a standard website crawler or screenshot tool satisfy CARS Act archiving requirements?

No. Standard crawlers and screenshot tools capture only the static HTML shell of a page. California dealer websites are JavaScript-heavy single-page applications where pricing, incentives, payment calculators, Buy/Lease/Finance tabs, and promotional modals only render after scripts execute. A crawler that cannot execute JavaScript will miss the exact dynamic elements SB 766 puts in scope. A defensible CARS Act archive requires full-fidelity rendered-state capture — preserving what the consumer actually saw.

What is the penalty for not complying with CARS Act archiving requirements?

SB 766 gives regulators and consumers the ability to request archived records. A dealer who cannot produce a timestamped, defensible archive of their advertising has no compliant response to an audit or complaint. Violations can expose dealers to regulatory action and civil liability under California consumer protection law.

When does California SB 766 take effect?

California SB 766 takes effect 1 October 2026. The two-year retention clock starts from the first advertisement served on or after that date.

How does MirrorWeb archive dealer VDPs for CARS Act compliance?

MirrorWeb uses a fully managed, headless-browser capture pipeline that executes JavaScript, renders dynamic elements, and preserves the complete customer-facing experience — including payment calculators, expandable disclosures, modals, carousels, and Buy/Lease/Finance tabs. Captures are timestamped, stored in a tamper-evident archive, and searchable by date, URL, or content. No dealer-side software or IT involvement required.

Does CARS Act archiving apply to third-party marketplace listings like CarGurus or AutoTrader?

Yes. SB 766 covers internet-based advertisements served to California consumers, which includes third-party marketplace listings on CarGurus, AutoTrader, Cars.com, and similar platforms that display a vehicle's price, features, or financing terms. Dealers should ensure their archiving solution covers both first-party VDPs and third-party listings.

CARS Act Archiving for California Auto Dealers

OBLIGATION 1

Two-year advertisement retention

Every internet-based advertisement displaying a vehicle's total price, features, or financing terms must be retained in retrievable form for two full years from the date it was served to a California consumer.

In scope

Vehicle detail pages (VDPs)
Price and incentive disclosures
Financing and lease terms
Dealer add-on and fee disclosures

OBLIGATION 2

Full-fidelity dynamic content capture

Modern dealer websites render pricing, payment calculators, and promotional content via JavaScript after page load. SB 766 requires the archive to reflect what the consumer actually saw; not a static HTML shell.

Dynamic elements that must be captured

Payment calculators and rate modals
Buy / Lease / Finance tabs
Expandable disclosures and carousels
Promotional pop-ups and overlays

OBLIGATION 3

48-hour vehicle removal rule

When a vehicle is sold or removed from inventory, its listing must be taken down within 48 hours. The archive must be able to prove the date and time of removal; not just that it eventually came down.

What this means in practice

Timestamped capture at point of display
Searchable by URL, vehicle, and date range
Audit-grade export for regulatory requests
Tamper-evident chain of custody

Standard crawler or screenshot tool

❌ Captures static HTML only

Payment calculators, modals, and financing tabs render via JavaScript after page load. A standard crawler sees an empty container — not the price the consumer saw.

❌ No tamper-evident chain of custody

Screenshots and file exports can be altered. A defensible archive requires cryptographic timestamping and an immutable audit trail.

❌ Cannot prove what was displayed, when

Regulators want to know what a specific consumer saw on a specific date. A static snapshot library cannot answer that question reliably.

MirrorWeb CARS Act archiving

✔️ Full-fidelity rendered-state capture

MirrorWeb executes JavaScript, waits for all dynamic elements to resolve, and preserves the complete customer-facing experience — exactly what the consumer saw.

✔️ Tamper-evident, timestamped storage

Every capture is cryptographically signed and stored in an immutable archive with a verifiable chain of custody. Regulators can trust it because it cannot be altered.

✔️ Searchable by date, URL, or content

When a records request arrives, search by vehicle, date range, or keyword and produce the exact archived state in minutes — not weeks of manual recovery.

STEP 01

Automatic VDP discovery

MirrorWeb continuously discovers all vehicle detail pages across the dealer's website — including dynamically generated inventory URLs — without any manual configuration or dealer-side tagging.

STEP 02

Full-fidelity rendered capture

A headless browser executes JavaScript, resolves all dynamic elements, and captures the complete rendered state — payment calculators, modals, tabs, disclosures — exactly as the consumer sees it.

STEP 03

Timestamped, tamper-evident storage

Every capture is cryptographically signed, timestamped, and stored in an immutable archive for a minimum of two years. Chain of custody is maintained for every record, from capture to retrieval.

STEP 04

Searchable, audit-ready retrieval

When a regulator or attorney requests records, search by vehicle, date, URL, or content and export a verifiable archive package in minutes. Built for the audit, not just the storage requirement.

CARS Act Archiving
for California Auto Dealers