Selling car rental: complying with consumer law
Published 29 March 2018
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If you provide a service for people to book car rental, then the prices and other essential information you show must be accurate, clear and prominent. If it’s not, you risk breaking the law.
It’s important that your customers know the actual cost of their car rental and are provided with details of any additional liabilities - such as the excess or deposit amounts - they may be exposed to. This is so they can make an informed choice about which deal is best for them.
We strongly recommend you read the CMA’s consumer law compliance summary, available on the car rental intermediaries case page which sets out the steps you should take to comply with consumer law in the following areas.
Information you display
The information you display must be accurate.
You must have procedures in place to limit the risk of showing inaccurate prices. Your website must show accurate information and you must regularly monitor this. Remember, you may also be liable if you show inaccurate prices even if your supplier is at fault.
Require your suppliers to include compulsory charges and other key information in their data feeds to you. You should have a policy in place on how to deal with suppliers who regularly provide inaccurate prices. If necessary, stop listing offers from suppliers who don’t comply.
Price
The headline price must include all compulsory charges.
Once the customer has entered their search details, the prices they are shown must be the total cost, including compulsory charges such as fuel and age-related surcharges, out of hours fees, taxes and one-way fees.
Charges are compulsory if customers cannot avoid them. These charges should not be added late in the booking process or at the rental desk.
You must provide details of the fuel policy.
If you rank offers on price it must be on the whole price (including any charges paid on pick-up) to avoid making misleading comparisons.
Customer liabilities
The customer must be told their liabilities
You must clearly and prominently state the amount of the excess on the collision damage waiver and the amount of any deposit or credit card pre-authorisation, if this is required. This information should be no more than one click away from the headline price, for example, in a ‘key facts’ document or by clicking an icon in the search results.
Best practice is to place a prominent warning on your website advising customers to check the excess and the amount of the deposit before completing their bookings.
Warnings about items that are legal requirements, such as snow chains or child seats, should be flagged when these options are offered.
Your website should treat people fairly, and must be Clear, Accurate, Responsible and Easy to use (CARE)
Why it matters
Customers need information that is accurate, current, easy to find and not misleading. This helps them choose the deal that is best value for their needs.
If your website displays inaccurate or misleading information and you fail to check it or keep it up-to-date, then you risk breaking consumer protection law.
The information provided above does not constitute legal advice and should not be relied upon as such.