Steps to Register a Franchise Disclosure Document (FDD)

Steps to register an fdd

Written by The Internicola Law Firm Team
Reviewed by Charles N. Internicola, Esq., Founder | Chambers USA Recognized | Ranked #1 Franchise Law Firm in the U.S. by Entrepreneur Magazine (2025)

Last Updated: July 2026

The direct answer: Before offering or selling a franchise, every franchisor must issue an FDD that complies with the FTC Franchise Rule — and in 13 franchise registration states, the FDD must also be registered with the state regulator before any offer or sale. In 9 filing states, a notice or exemption filing is required instead. The process: identify the states involved in your franchise sale, determine each state's registration or filing status, and submit the required application — through NASAA's Electronic Filing Depository (EFD) in eight states, or through state-specific systems like California's FRANSES. Registration takes anywhere from 20 days to three months depending on the state, the season, and the completeness of your FDD.

The Three Steps to Register or File Your FDD

Under the franchise laws, a franchisor must issue and properly disclose a Franchise Disclosure Document (FDD) before offering or selling a franchise. At the federal level — and in many states — there is no requirement to register an FDD. But in the 13 states referred to as the franchise registration states, a franchisor must first register its FDD with the state franchise regulator before offering or selling a franchise in the state, and in the 9 states referred to as the franchise filing states, a franchisor must first file a notice with the designated state regulator.

The steps involved in registering or filing your FDD at the state level:

1. Identify the State(s) Involved in the Franchise Sale — More than one state may be involved. Factors to evaluate with your legal counsel include: (a) the state where the franchised business will be established; (b) the franchisee's state of residence; (c) any state where franchise sales activities or negotiations occurred; and (d) the state from which your franchise company operates.

2. Determine Each State's Registration or Filing Status — Determine the FDD registration and filing status of every state involved in your franchise sale. Our interactive franchise registration map covers all 50 states.

3. Register or File Your FDD — In a registration state, you must file a Uniform Franchise Registration Application with the designated state regulator, including your FDD and the state's registration fee, which the state will then review. In filing states, each state requires its own notice or exemption process. Fees and processes vary state by state. 

→ See what registration costs in every state

We help franchisors register their FDDs timely and cost-effectively and keep franchise sales up and running. Call (800) 976-4904 to learn more.

Franchise Registration States

For franchisors that have a federally registered trademark, the franchise registration states are California, Hawaii, Illinois, Indiana, Maryland, Michigan, Minnesota, New York, North Dakota, Rhode Island, Virginia, Washington, and Wisconsin. Each registration state designates an entity to regulate the franchise registration process and requires annual FDD registration. (Reference to a federally registered trademark refers to the primary trademarks of your franchise system.)

Additional registration states if you do not have a federally registered trademark: if your primary trademarks are not registered with the United States Patent and Trademark Office (USPTO), then you must also register your FDD in Connecticut, North Carolina, South Carolina, and Maine.

Franchise Filing States

For franchisors that have a federally registered trademark, the franchise filing states are Connecticut, Florida, Kentucky, Nebraska, North Carolina, South Carolina, South Dakota, Texas, and Utah.

Additional filing states if you do not have a federally registered trademark: you must also file with Georgia and Louisiana. These filings are limited to a consent to service of process.

How Registrations and Filings Are Actually Submitted

There is no single national system for franchise filings. Eight states accept or require filings through NASAA's Electronic Filing Depository (EFD) — Illinois, Maryland, New York, North Dakota, Rhode Island, South Dakota, Virginia, and Nebraska — with New York and North Dakota requiring EFD, which charges its own processing fee ($100 per initial filing, $50 per renewal). California files through its own FRANSES system, Minnesota through ComOnline, and Indiana, Hawaii, Utah, and Florida through their own state processes, while Washington and Wisconsin accept direct online submission. For every state's system and the real fees involved — including processing fees — see the cost to register your franchise in multiple states.

How Long Does FDD Registration Take?

Timing varies from state to state, and FDD registration can take anywhere from 20 days to three months depending on the completeness of your FDD and the time of year it is filed. Learn more about when FDDs expire and require renewal.

The Uniform Franchise Registration Application

Although each registration state publishes its own requirements, forms, and filing fees, your registration application will be based on forms and instructions published by the North American Securities Administrators Association (NASAA), with state-specific supplements and disclosure variations. Generally, your franchise registration application will include:

  • The Uniform Franchise Registration Application page with data on the franchisor;
  • The certification (signature) page;
  • A Consent to Service of Process;
  • The Sales Agent Disclosure Form and Franchise Seller Disclosure Form;
  • The Supplemental Information Form;
  • Copies of advertising or promotional literature proposed to be used in the state;
  • Your FDD, submitted through the applicable filing system;
  • The auditor's consent; and
  • The application fee.

As a franchisor, you need to understand the franchise registration process: failure to comply with and properly manage state registrations will harm your franchise sales process and may create significant liability exposure.

More FDD Registration and Renewal Information

For state-by-state registration and filing information, visit our interactive franchise registration map. For information about what registration actually costs in every state, see the cost to register your franchise in multiple states. For a complete overview on renewaing your FDD, see The FDD Renewal Guide.

Questions About Your FDD Registrations?

From your first registration to a 50-state footprint, we help franchisors get it right in every state — 350+ franchise brands. Call (800) 976-4904 or complete the form below.

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