California's Honest Pricing Law: a compliance brief

California SB 478 amended the Consumer Legal Remedies Act (CLRA) to prohibit "advertising, displaying, or offering a price for a good or service that does not include all mandatory fees or charges," with two narrow exceptions: government-imposed taxes and fees, and reasonable shipping costs for physical goods.

The statute does not regulate how much a business can charge or what it can include in price; it regulates how the price is presented. The first price a consumer sees must be the price they can actually pay (other than tax and shipping).

• All mandatory business-imposed fees must be in the first advertised price.
• Government-imposed taxes and fees may be excluded.
• Reasonable shipping for physical goods may be excluded.
• Optional add-ons (true upgrades a consumer can decline) are not "mandatory."

SB 478 applies to any business that advertises, displays, or offers a price to California consumers — regardless of where the business is headquartered. Hotels, short-term rentals, ticketing platforms, subscription services, food delivery, and event venues are all squarely within scope.

Two companion bills are relevant to specific industries: SB 1524 carved out a restaurant exception (signed June 29, 2024), and AB 537 (codified at Cal. Bus. & Prof. Code § 17568.6, also effective July 1, 2024) imposes a parallel transparent-pricing requirement on short-term lodging with civil penalties of up to $10,000 per violation enforceable by the California Attorney General, district attorneys, and city attorneys.

SB 1524, signed days before SB 478 took effect, exempts a mandatory fee or charge for individual food or beverage items sold by a restaurant, bar, food concession, grocery store, or grocery delivery service — but only if the fee is "clearly and conspicuously displayed, with an explanation of its purpose, on any advertisement, menu, or other display that contains the price of the food or beverage item."

The exception is narrow: a service fee added to a dine-in tab can be permissible if disclosed on the menu next to prices; a hidden "kitchen appreciation" fee that first appears on the check is not.

SB 478 violations are enforceable under the Consumer Legal Remedies Act. Consumers may recover actual damages (with a $1,000 floor in class actions), restitution, punitive damages, injunctive relief, and attorneys' fees. The Unfair Competition Law (UCL) provides additional civil-penalty exposure when the conduct is prosecuted by the Attorney General, district attorneys, or city attorneys.

Private plaintiffs and class actions are an active enforcement channel. Pre-suit notice and right-to-cure provisions apply for damages claims under the CLRA but not for injunctive relief.

• Hotel rate displayed without resort or destination fees included in the headline price.
• Event ticket price shown before service and facility fees are added at checkout.
• Subscription advertised at the monthly rate without disclosing a mandatory onboarding or activation fee.
• Auto listing showing the sticker price while doc and dealer fees appear only at signing.
• Restaurant menu charging a service fee or kitchen appreciation fee without conspicuous disclosure on the menu.