Franchise Disclosure Register Compliance: ACCC Issues Fresh Warning to Franchisors

The Australian Competition and Consumer Commission (ACCC) has issued a timely reminder to franchisors across Australia: Your Franchise Disclosure Register profile must be accurate, complete, and up to date, or you risk enforcement action.

Franchise Disclosure Register compliance warning as the Australian Competition and Consumer Commission (ACCC) increases enforcement under the Franchising Code of Conduct in Australia.

This latest communication reinforces a growing regulatory focus on transparency and accountability within the franchising sector, particularly following the full implementation of the updated Franchising Code of Conduct.

Enforcement in Focus: $19,800 Penalty Issued

In March 2026, Luxottica Franchising Australia Pty Ltd paid a $19,800 penalty after allegedly failing to comply with its obligations under the Code.

The penalty followed an infringement notice issued by the ACCC for not keeping its Franchise Disclosure Register profile up to date.

While the financial penalty itself is relatively modest, the regulatory signal is not, the ACCC is actively monitoring compliance and prepared to take enforcement action where required.

Why the Franchise Disclosure Register Matters

The Franchise Disclosure Register plays a critical role in the franchising ecosystem. It is designed to improve transparency and allow prospective franchisees to make informed investment decisions.

From a legal and commercial standpoint, this aligns with core principles of disclosure and fair dealing embedded in Australian franchising regulation.

Franchisors should understand that:

• Prospective franchisees rely heavily on register data before entering agreements

• Inaccurate or outdated information can undermine trust and expose franchisors to regulatory scrutiny

• The register operates as a public-facing compliance tool, not just an administrative obligation

Key Compliance Obligations for Franchisors

Under the Franchising Code, franchisors must meet several specific requirements in relation to the Register:

1. Annual Updates Are Mandatory

Franchisors must confirm or update their profile every year to ensure ongoing accuracy.

2. Consistency with Disclosure Documents

Information uploaded to the Register must align with formal disclosure documents and comply with structured data requirements.

3. Registration Before Offering Franchises

New franchisors must register at least 14 days before entering into any franchise agreement. This mandatory waiting period is designed to give prospective franchisees sufficient time to review the information.

4. Complete and Accurate Profiles

Profiles must not be partial, outdated, or misleading, completeness is a compliance requirement, not a best practice.

The 2025 Code Changes: Raising the Compliance Bar

The updated Franchising Code of Conduct came into effect in April 2025, with remaining provisions commencing on 1 November 2025.

This means the regulatory framework is now fully operational, and expectations on franchisors have materially increased.

The ACCC has made it clear that the Register will be actively monitored as part of its broader compliance and enforcement strategy.

What This Means for Franchisors

For franchisors, this is not an administrative detail, it is a legal risk issue.

Failure to maintain an accurate Franchise Disclosure Register profile can result in:

• Infringement notices

• Financial penalties

• Increased regulatory scrutiny

• Potential reputational damage

More importantly, non-compliance may signal broader governance issues within a franchise system.

How Bane Legal Services Can Help

Staying compliant with the Franchising Code requires more than simply uploading documents, it demands alignment between your legal documentation, operational practices, and regulatory obligations.

Bane Legal Services is not a law firm and does not provide legal advice.

Instead, we act as your trusted legal matchmaker, connecting franchisors and business owners with experienced commercial lawyers who understand:

• Franchise compliance and disclosure obligations

• ACCC enforcement trends

• Risk mitigation strategies for franchise networks

With over 30 years of business experience, we help ensure you are matched with the right legal expertise to protect and scale your franchise system with confidence.

Source Attribution

This article is based on a media communication issued by the Australian Competition and Consumer Commission (ACCC) regarding Franchise Disclosure Register compliance obligations and recent enforcement activity.