Key Takeaway points
- If you’re a franchisor with a 30 June financial year end, you need to update your disclosure document by 31 October 2026 to stay compliant with the Franchising Code of Conduct.
- Since 1 November 2025, franchisors must compensate franchisees for early termination and give them a reasonable opportunity to make a return on their investment. Make sure your agreements already meet these requirements.
- You also need to confirm or update your details on the franchise disclosure register by 14 November 2026.
- The ACCC has increased its enforcement budget for the new Code and is expected to step up compliance action through 2026, so it pays to act early.
If you’re a franchisor with a 30 June financial year end, you have three deadlines to work towards. If you operate a specific purpose fund, you need to ensure that financial statements for the fund have been prepared and audited (if applicable), by 31 October 2026. In addition and also by 31 October 2026, you need to update your disclosure document. By 14 November 2026, you need to confirm or update your details on the Franchise Disclosure Register. These are requirements under the Franchising Code of Conduct, and the ACCC has flagged continued enforcement action through 2026. Below, we set out exactly what to check in your disclosure document, the rules that have applied since 1 November 2025, and what you need to update on the register.
The issue
The ACCC has already acted against franchisors who missed these deadlines. In June 2025, Cash Converters and MTA Mobile Travel Agents were each issued a $16,500 penalty for failing to update their register information. In August 2025, a Queensland based Harvey Norman franchisor was fined $15,650 for not including required information on the register before signing an agreement with a franchisee. The ACCC has since increased its enforcement budget for the new Code, and more frequent action is expected through 2026.
These penalties are small compared to what’s possible. As at 1 July 2026, failing to comply with a provision of the code can attract a penalty of up to $218,400. Failing to disclose financial information or other material changes, such as a change in ownership, court proceedings, or a change to your intellectual property, can attract a penalty of $10,000,000, three times the benefit you gained from not complying, or 10% of your annual turnover, whichever is greater (to be confirmed).
Your disclosure document and register details also need to be accurate and up to date before you enter into an agreement with a new franchisee. If they’re not, you risk delaying a deal and exposing your business to penalties.
What you need to do
1. Update your disclosure document by 31 October 2026
Your disclosure document needs to be updated within four months of the end of your financial year. If your financial year ends on 30 June, your deadline is 31 October 2026.
When you update it, a thorough review is recommended, however you should check these items carefully:
- any changes to your officers or associates;
- any changes to your intellectual property;
- details of any litigation you’ve started or finished;
- the fees, costs and expenses payable by franchisees;
- details of franchisees who have joined or left your system in the last three years;
- your financial details, including a solvency statement from your directors.
2. Make sure you’re meeting the rules that started 1 November 2025
Two rules have applied since 1 November 2025:
- you must provide franchisees with compensation if you terminate their agreement early in relevant circumstances;
- you must give franchisees a reasonable opportunity to make a return on the investment you’ve required them to make.
If you haven’t already reviewed your franchise agreements against these requirements, do this as a priority. The transition period for these rules has ended, and the ACCC is expected to scrutinise compliance more closely in 2026.
3. If you run a marketing fund or other specific purpose fund
If your franchisees contribute to a fund for a specific purpose, such as a marketing fund, you need to prepare a financial statement covering all income and expenses for the past financial year.
This statement needs to be audited by a registered company auditor, unless 75% of your franchisees vote against this within three months of the end of the financial year. Prepare the statement and auditor’s report within four months of the end of your financial year and give a copy to your franchisees within 30 days of preparing it.
4. Update the franchise disclosure register by 14 November 2026
Within 14 days the fifth month of the end of your financial year (for example, 14 November), update your details on the register, including:
- your business name, ABN (if you have one), registered address and principal place of business;
- basic details about your franchise system, including how long you’ve operated, your number of franchisees, your use of suppliers, payment and cost information, the term of your agreements, renewal options and any restraint of trade provisions;
- your business phone number and email address;
- the ANZSIC division and subdivision codes for your industry.
The ACCC updated the form and manner requirements for the register, effective 30 March 2026. If you’re creating a new franchise profile or updating an existing one, check you’re using the current format.
Summary and key dates
To stay compliant with the Franchising Code of Conduct and avoid ACCC penalties, add these dates to your calendar:
- 31 October 2026: ensure any specific purpose fund has financial statements prepared and audited (if applicable), as well as provide those financial statements to franchisees within 30 days of preparing it;
- 31 October 2026: update your disclosure document (if your financial year ends 30 June);
- ongoing: make sure your franchise agreements meet the requirements for early termination compensation and reasonable return on investment, which have applied since 1 November 2025; and
- 14 November 2026: confirm or update your details on the Franchise Disclosure Register, using the updated form and manner requirements from 30 March 2026.
The ACCC has increased its enforcement budget and is expected to take more frequent action through 2026, including over what might seem like administrative details. Getting your disclosure document and register information right now means one less thing to worry about, and keeps you ready to sign new franchisees without delay.
Need help updating your disclosure document or reviewing your franchise agreements before these deadlines? Get in touch with our Franchising team.
