The Franchise Disclosure Register: What Franchisors Need to Know About Compliance
Introduction
The Franchise Disclosure Register is designed to promote transparency and assist prospective franchisees in making informed decisions. The obligations apply to franchisors imposed by the Competition and Consumer (Industry Code – Franchising) Regulations 2024 (Franchising Code).
Recent enforcement action by the Australian Competition and Consumer Commission (ACCC), including penalties imposed on a number of franchisors for Register-related contraventions, demonstrates that compliance is an active enforcement priority for the ACCC.
This article outlines the key obligations imposed on franchisors in relation to the Franchise Disclosure Register, the information that must be disclosed and maintained, and recent ACCC enforcement activity.
Franchise Disclosure Register
The Franchise Disclosure Register is a free, publicly available online platform containing information about franchise systems in Australia. It is the equivalent of the ASIC register for companies, save this is for franchise systems.
It includes information about setup costs, ongoing payments, franchise system size and distribution. Introduced in 2022, the Franchise Disclosure Register published aim was to improve transparency for prospective franchisees.
Under Regulations 92-93 of the Franchising Code, all franchisors must:
create a franchise profile on the Franchise Disclosure Register and publish business information on it;
join the Franchise Disclosure Register at least 14 days before entering into a franchise agreement; and
confirm or update the information in their franchise profile on the Franchise Disclosure Register by a specific date every year. The due date will depend on the financial year the franchise business operates in – profiles must be confirmed or updated before the 14th day of the 5th month after the end of the franchise business’ financial year. For example, if a franchisor uses the Australian financial year (1 July – 30 June), the franchisor must confirm of update the information in their profile by 14 November each year.
If franchisors fail to abide by these requirements, they may face a civil penalty of up to 600 penalty units ($218,400 as of the time of writing).
There is an exception: master franchisors are exempt from being on the Franchise Disclosure Register if they only have one Australian sub-franchisor.
Upon the Franchise Disclosure Register’s inception in 2022, the following information was mandated to be published:
franchise name and ABN (if applicable);
name under which the franchise conducts business in Australia;
the franchise’s telephone number and email address;
the address of the franchise’s registered office and principal place of business in Australia;
the franchise’s ANZSIC division and subdivision;
any other information required by the Secretary under s 92(4) of the Franchising Code.
The above list was extended under the new Franchising Code to include:
whether a franchisor, a director of the franchisor, an associate of the franchisor or a director of an associate of the franchisor has been convicted of a serious offence, been subject to a final judgment in civil proceedings regarding certain matters, or been bankrupt or insolvent, within a certain time period; and
whether a franchise agreement provides for arbitration of disputes.
Franchisors may also choose to voluntarily publish a copy of their standard franchise agreement.
ACCC enforcement
In August of 2025, then ACCC Deputy Chair Catriona Lowe announced “the franchising sector should be on notice that failure to comply with the [Franchising Code] may result in enforcement action by the ACCC”.
This followed the Government’s announcement to provide $7.1 million over 2 years to strengthen the ACCC’s enforcement of the Franchising Code.
In June – August of 2025, a Harvey Norman franchisor, Cash Converters franchisor and Mobile Travel Agents franchisor all paid penalties for non-compliance with the Code after allegedly failing to abide by their Franchise Disclosure Register requirements.
The franchisors of Cash Converters and Mobile Travel Agents each paid penalties of $16,500 by allegedly failing to annually update their franchisor information on the Franchise Disclosure Register. The Harvey Norman franchisor paid a $15,650 penalty for allegedly failing to include mandatory information on the Franchise Disclosure Register at least 14 days before entering into a new franchise agreement with a prospective franchisee.
In March of 2026, Luxottica Franchising Australia (which trades as eyewear retailers Laubman & Pank and OPSM) paid a penalty of $19,800 after allegedly failing to maintain an up-to-date profile on the Franchise Disclosure Register.
In response, current ACCC Deputy Chair Mick Keogh remarked that “failure to update the register compromises transparency and may mislead prospective franchisees, so all franchisors should be aware of their obligations to comply with the [Franchising Code] and update their profiles annually with accurate information.”
Earlier this month, on 3 August 2026, the ACCC announced that franchise operator Venue Smart Pty Ltd (trading as Venue Smart) paid $59,400 in penalties for alleged contraventions of the Franchising Code. The ACCC sent penalty notices to the franchisor, alleging it breached the Franchising Code by, among other things, failing to provide the required information for inclusion on the Franchise Disclosure Register at least 14 days before entering into a franchise agreement with a prospective franchise.
Key Takeaways
The ACCC’s enforcement activity demonstrates a strong expectation that franchisors comply with their disclosure requirements for the Franchise Disclosure Register.
Franchisors should ensure their Franchise Disclosure Register profiles are accurate, complete and updated within the required timeframe to minimise the risk of enforcement action and financial penalties. Including this in a compliance risk register with regular review dates will minimise the risk of contravention.
if you have any queries, please contact:
Alicia Hill
Principal
T: +61 3 9611 0180 | M: +61 484 313 865
E: ahill@sladen.com.au
Krissy Lamont
Associate
T: +61 3 9611 0175
E: klamont@sladen.com.au
This article was prepared with the assistance of Chris Downes, Law Clerk.
