From 1 April 2025, all franchisors in Australia must use the updated Franchise Disclosure Document format under the revised Franchising Code of Conduct.
If you’re a franchisor (or advising one), here’s the bottom line: regulators and prospective franchisees will quickly spot whether your disclosure documents are compliant—or not.
As franchise lawyers who regularly prepare and review Disclosure Documents for both franchisors and franchisees, we’ve already seen the impact of these changes in action. Here’s what you need to know.
What’s Changed in the Franchise Disclosure Document (Effective 1 April 2025)
New Numbering System
Disclosure Documents now follow a revised numbering structure. Old references like 14.1 or 14.2 may no longer match the updated format.
No More Key Facts Sheet
The Key Facts Sheet has been scrapped. Any reference to it must be removed.
Instead, franchisors must provide the Information Statement from the ACCC.
Section 10 – Competition Disclosure
Franchisors must now disclose whether a franchisee might face competition from businesses not affiliated with the franchise network.
Section 14(1A) & 14(1B) – Capital Expenditure
If you require franchisees to make a significant capital investment, you now need to spell out:
The reason for the expense
The amount, timing, and type of expenditure
The expected benefits
Any associated risks
This is especially relevant where fit-outs, equipment upgrades or refurbishments are involved.
Section 15 – Marketing and Other Funds
The term “marketing fund” is no longer enough. Disclosure must now refer to specific proposed funds, including:
The purpose of the fund
How contributions will be used
Why This Matters for Franchisors
These aren’t just formatting tweaks. They go to the heart of your franchisee relationships and legal obligations. A non-compliant Disclosure Document puts you at risk of ACCC scrutiny, disputes, or delays in onboarding new franchisees.
Franchise lawyers who are across these updates are already:
Updating client disclosure templates
Reviewing franchise systems for compliance gaps
Educating franchisors on their new obligations
Do You Need to Update Your Franchise Disclosure Document?
If you haven’t reviewed your documentation yet, now’s the time. Don’t wait until a franchisee—or regulator—calls it out.
Need help updating your Disclosure Document to meet the 2025 Franchising Code changes?
Our team can help you stay compliant, reduce your risk, and protect your franchise network. Book in for a free no-bligation chat with one of our franchise team.
Remember, while this information provides a general overview, legal advice tailored to your specific circumstances is invaluable. Don’t hesitate to contact Rise Legal for personalised guidance or book in a free Discovery Call.
Disclaimer: This blog post is intended for informational purposes only and should not be considered legal advice. Consult with a qualified commercial lawyer for personalised advice related to your specific circumstances.
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