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Home Franchise Your Business When Does an FDD Expire and Require Renewal?

Under the Federal franchise laws  FDDs expires annually and must be updated within 120 days of a franchisors fiscal year end. For franchisors that operate on a fiscal calendar year, their FDD will expire on April 30th of each year. Prior to expiration, franchisors must update their FDDs and, within the franchise registration states, renew their state registrations. At the state level, FDD update requirements and expiration dates can vary from state-to-state and from federal requirements.

Below is a chart listing the FDD registration, filing, and renewal requirements on a state-by-state basis, including FDD expiration dates:

State Registration or Filing State State Expiration Dates
California Registration Annual registration required. Expires 110 days after your fiscal year end.
Connecticut Registration / Exemption If you have a federally registered trademark, then one-time exemption filing that does not expire. If you do not have a federally registered trademark then you must register annually. Registration expires 1 year from registration effective date.
Florida Filing Annual filing required. Expires 1 year from filing effective date.
Hawaii Registration Annual registration required. Expires 90 days after your fiscal year end.
Illinois Registration Annual registration required. Expires 120 days after your fiscal year end.
Indiana Registration Annual registration required. Expires 1 year from registration effective date.
Kentucky Filing One time filing only; no expiration.
Maine Filing / Exemption If you have a federally registered trademark, then no filing required. If you do not have a federally registered trademark then filing required. Filing expires 1 year from filing effective date.
Maryland Registration Annual registration required. Expires 1 year from registration effective date.
Michigan Registration Annual notice filing required. Expires 1 year from notice filing date.
Minnesota Registration Annual registration required. Expires 120 days after your fiscal year end.
Nebraska Filing One time filing; no expiration.
New York Registration Annual registration required. Expires 120 days after your fiscal year end.
North Dakota Registration Annual registration required. Expires 120 days after your fiscal year end.
Rhode Island Registration Annual registration required. Expires 1 year from registration date; must submit renewal 30 days prior to expiration.
South Carolina Filing / Exemption One time filing if you have a registered trademark.
South Dakota Filing Annual filing required. Expires 1 year from filing effective date.
Texas Filing One time filing; no expiration.
Utah Filing Annual Filing is required. Expires 1 year from filing effective date.
Virginia Registration Annual registration required. Expires 1 year from registration effective date.
Washington Registration Annual registration required. Expires 1 year from registration effective date.
Wisconsin Registration Annual registration required. Expires 1 year from registration effective date.

How to Resolve Conflicts Between State Renewal Requirements and the 120 Day Federal Rule

Many times a conflict exists between the date that your FDD must be updated under the federal franchise rule and the date that your state registrations and filings must be updated.

Using Virginia State as an Example: If, for example, your franchise company operates on a fiscal calendar year basis and your most recent Virginia state registration occurred on October 1st. Under the federal 120-day rule, your FDD will expire on April 30th. Even though under Virginia law your registration lasts for one year and will remain effective until October 1st, as of April 30th your FDD will have expired and you must stop selling franchises in Virginia on April 30th. In this example, prior to April 30th the appropriate course of action is to file for FDD registration renewal with Virginia. At the time of making this filing you could request that Virginia change the effective date of your registrations so that it is in sync with the federal 120-day requirement.

Quarterly and Immediate FDD Updates

If there is a material change in the information disclosed in your FDD, then you must update your FDD within the next quarter. Once updated, you will be required to update your state registrations through a post-effective amendment process. If a change relates to facts or information that would influence the decision-making process of a reasonable franchisee then you should consider such change as material and as one that triggers an FDD update. Changes in information related to your Item 19 Financial Performance Representations must be made immediately.

Need help renewing your FDD this year? Contact us to learn about how we can help.

Learn more about State Franchise Laws and Registration Requirements.

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