Annual Franchise Disclosure: Get Your House In Order Before 31 October
Most franchisors treat annual disclosure as an admin job. Hand it to the accountant, ring the lawyer in the last week of October, hope for the best.
That is how systems end up in front of the regulator.
If your financial year ends on 30 June, the clock is already running. Here is what actually needs to happen, and where franchisors get caught.
The Three Dates That Matter
The annual update to your disclosure document must be made within four months of the first day of your financial year, so for a 1 July start it is due by 31 October. Your Franchise Disclosure Register profile must be updated or confirmed before 14 November.
Miss either and you are in breach. The ACCC is explicit that failing to update the register each year means a breach of the Code and penalties may apply.
Fund Audit Vote: The Date Nobody Remembers
If franchisees pay into a marketing fund, the fund's annual financial statement must be audited. The only exception is where 75% of contributing Australian franchisees vote that an audit is not necessary, and that vote should happen within 3 months after the end of the financial year.
For a 30 June year end, that is 30 September. Miss the window and the audit is compulsory. No vote, no waiver.
Your Marketing Fund Is Probably Not Your Only Fund
The new Code replaced the old marketing fund concept with the broader specific purpose fund. That now captures conference funds and IT or development funds as well.
Calling something a "technology fee" does not change how the money actually works. If franchisees are required to pay into a pool used for a common network purpose, treat it as a fund until your lawyer tells you otherwise.
The obligations are not light. The financial statement and any audit report must be prepared within four months of year end, and the statement goes to franchisees within 30 days of being prepared. If you operate a franchised business yourself, you must contribute to the fund like your franchisees do. The new Code also requires a copy of each fund's annual financial statement to be included in the disclosure document.
The ACCC Is Not Bluffing
This is the part franchisors like to skip. It is also the most persuasive.
Delicia Franchising paid $11,100 for failing to give franchisees its marketing fund financial statement, and the ACCC found the statements lacked sufficient detail on receipts and expenses. More recently, Venue Smart paid $59,400 in August 2026 after three infringement notices, covering a missing marketing fund financial statement, no separate account for franchisee marketing payments, and late register information. In March 2026, Luxottica Franchising Australia paid $19,800 for allegedly failing to keep its register profile up to date.
Notice the pattern. These are not fraud cases. They are basic housekeeping failures.
What Your Disclosure Update Must Actually Contain
It is not a date change. The document must follow the Schedule 1 format, and franchisors must update their solvency statement when they update the disclosure document. It must also cover future capital expenditure franchisees may have to pay, including significant capital expenditure.
And if a significant change hits your system mid-year, you cannot sit on it until the next annual update. Materially relevant facts have to be disclosed.
One practical point. The ACCC has said it will accept franchisors maintaining one disclosure document that complies with the new Code, without the annual key facts sheet the old Code required. If yours still has one, it is not a cosmetic fix. It is a sign the document has not been properly rebuilt.
Sort Your Register Access Now
To reach the franchisor dashboard you need a personal Digital ID and authority to act for the business in the ATO's Relationship Authorisation Manager. If the person who normally handles this has left, or nobody holds that authority, you find out on 13 November. Not a good day.
Then treat the profile as what it is: A public sales page. The ACCC does not review or vet what franchisors publish on the register. Anyone reading it, including a prospect, a competitor or a journalist, will judge you on it. Keep it consistent with your disclosure document. The ACCC also updated the form and manner of the register from 30 March 2026, so do not assume last year's answers still fit.
Your One-Month Plan
This week: Confirm whether you operate any specific purpose fund and whether the audit vote was held.
Now: Get your accountant moving on the financials and solvency statement.
Mid October: Rebuild the disclosure document line by line, including capital expenditure.
Late October: Sign it, remove the old version from circulation, and annex fund statements.
Before 14 November: Update or confirm the register, prepared in a document first, not typed live.
The Real Issue
Compliance is not the hard part. Numbers that do not hold together are.
If your fee structure, capital expenditure and fund reporting are not built on a sound commercial model, disclosure just exposes it, in writing, to every franchisee and prospect.
That is exactly what we fix at Franchising Made Easy®. Structure first, documents second.
If you want your system built properly before the next compliance season, look at the VIP Franchise Development Program.
Speak With a Franchise System Architect
If you are exploring franchising and want to determine whether your business may be ready for franchising, understanding the development process is an important first step.
At Franchising Made Easy®, we help founders design franchise systems that are structurally integrated and capable of sustainable growth.
If you would like to explore how franchising could work for your business, consider speaking with an experienced Franchise System Architect.
