Attorney General Brown Announces Launch of Inaugural Franchise Renewal Fast-Track Review Program

Published: 10/28/2025

​​​​​​​​​​FOR IMMEDIATE RELEASE

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BALTIMORE, MD – Attorney General Anthony G. Brown announced the establishment of a Franchise Renewal Fast-Track Review Program (Fast-Track Program). The Fast-Track Program is designed to encourage eligible franchisors to submit renewal applications early in the renewal cycle, with the goal of enabling the Attorney General’s Securities Division to more efficiently review and renew the filing.

Franchise registration and disclosure requirements were put in place to provide franchisees with necessary and complete information about franchise offers and to promote fair dealing in the franchisor-franchisee relationship. The Federal Trade Commission (FTC) is charged with enforcing the Amended Franchise Rule at the federal level, with states enforcing their own laws and regulations that govern franchise activity under their jurisdictions.

Maryland is one of twelve franchise registration states (along with California, Hawai‘i, Illinois, Indiana, Minnesota, New York, North Dakota, Rhode Island, Virginia, Washington, and Wisconsin) that require a franchisor to obtain a state registration to offer and sell franchises in the state. The Franchise Disclosure Document (FDD) typically is updated and renewed annually for a franchisor to continue to offer and sell franchises in those states in subsequent years.

The number of franchise renewal registration applications filed with the Securities Division has increased substantially in recent years, due to both the increased number of franchises and due to filing deadlines based on the franchisor’s fiscal year end. In 2024 and 2025, approximately two-thirds of the total applications filed each year were submitted from March through May, while less than 0.1% were submitted from January through February.

The Fast-Track Program is designed to allow franchisors with a fiscal year end between December 24 and January 7, and who have no pending enforcement matters with the Securities Division, to submit a franchise renewal application (including the FDD) by February 1, before the franchisor’s independent certified public accountant has completed the audit of the financial statements. The FDD submitted by the February 1 deadline is not required to include the audited financial statements. The Securities Division will then review and issue any deficiency comments quickly, allowing the franchisor to cure deficiencies and obtain pre-clearance of the FDD prior to the April 10 deadline for incorporating the audited financial statements into the FDD. The franchisor’s renewal FDD can then be registered by the Securities Division in April.

“This Fast-Track Program helps franchisors get their renewals processed more efficiently while maintaining the strong protections Maryland franchisees need and deserve,” said Attorney General Brown. “By spacing out the review process and reducing bottlenecks, we’re making it easier for businesses to operate in Maryland without compromising our oversight that protects franchisees.”

The inaugural Fast-Track Program will launch on January 1, 2026, with renewal applications due by February 1, 2026. The Fast-Track Program Guidelines and FAQ are posted on our website at https://oag.maryland.gov/i-need-to/Pages/securities-division.aspx.

The Securities Division will be holding webinars open to interested parties to discuss the Fast-Track Program and answer questions on Wednesday, October 29 at 2pm Eastern (click here: Maryland Fast Track Franchise Renewal Webinar) and Tuesday, November 4 at 2pm Eastern (click here: Maryland Fast Track Franchise Renewal Webinar).

Attorney General Brown thanks Maryland Securities Commissioner Melanie Lubin, Senior Assistant Attorney General Oludolapo “Tade” Osikomaiya, and Assistant Attorneys General Dale Cantone and Johanna Interian for their work developing the Fast-Track Program.

 

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