Franchise Registration States: Which States Require Registration Before You Sell

By SelectFranchiseList Editorial Team | Updated

Short answer: Thirteen states require a franchisor to register its Franchise Disclosure Document before offering or selling franchises there: California, Hawaii, Illinois, Indiana, Maryland, Michigan, Minnesota, New York, North Dakota, Rhode Island, Virginia, Washington and Wisconsin. Several other states, including Texas, Florida and Utah, require a notice or exemption filing instead.

Franchise registration states are US states that require a franchisor to file its Franchise Disclosure Document (FDD) with a state regulator, and in most cases wait for the registration to become effective, before offering or selling franchises to residents or for locations in that state. Registration is renewed every year.

State registration sits on top of federal law. The FTC Franchise Rule applies everywhere; state law decides where extra filings come first. This page lists the registration states, the filing states, and the procedural differences that affect a launch schedule.

Which states are franchise registration states?

The franchise registration states are California, Hawaii, Illinois, Indiana, Maryland, Michigan, Minnesota, New York, North Dakota, Rhode Island, Virginia, Washington and Wisconsin, according to 2026 guidance from Franchise Law Solutions. Each requires the FDD to be registered with the state regulator before any franchise offer or sale there.

StateRegistration requiredNotes from 2026 sources
CaliforniaYesMerit review; initial fee $1,865; advertising filing required
HawaiiYesState-run filing process
IllinoisYesAccepts NASAA Electronic Filing Depository (EFD)
IndianaYesEffective on receipt of filing package
MarylandYesMerit review; advertising filing required
MichiganYesEffective on receipt of filing package
MinnesotaYesFiles through ComOnline; advertising filing required
New YorkYesMerit review; EFD required; advertising filing required
North DakotaYesEFD required; advertising filing required
Rhode IslandYesAccepts EFD
VirginiaYesAccepts EFD
WashingtonYesDirect online submission; advertising filing required
WisconsinYesEffective on receipt of filing package

Why do some lists show 14 registration states?

Some lists show 14 registration states because they include South Dakota. Older and several current sources, including LegalClarity and FMS Franchise, still count South Dakota as a registration state, while Franchise Law Solutions classifies it as a state that requires an annual notice filing. Franchisors treat South Dakota as a state with a mandatory annual filing either way, so it never disappears from the compliance calendar.

Which states require a franchise notice filing instead?

Franchise filing states require a notice or exemption filing rather than full registration. For franchisors with a federally registered trademark, Franchise Law Solutions lists Connecticut, Florida, Kentucky, Nebraska, North Carolina, South Carolina, South Dakota, Texas and Utah. Most of these are one-time filings; Florida, South Dakota and Utah renew annually.

A filing state does not review the FDD on the merits. The franchisor files, pays the fee, and continues to follow the federal disclosure rule.

What is the difference between merit review and filing on receipt?

Merit review means a state examiner reads the FDD and issues comments that the franchisor must resolve before the registration takes effect. California, New York and Maryland are merit-review states and require an approval before sales begin, according to LegalClarity. Indiana, Michigan and Wisconsin treat registration as effective once the state receives a complete filing.

Merit review adds time to a launch. Franchisors that plan to sell first in New York or California build the comment cycle into their schedule.

Which states require franchise advertising to be filed?

California, Maryland, Minnesota, New York, North Dakota and Washington require franchisors to file franchise advertising, according to LegalClarity. In these states, franchise sales ads and marketing materials aimed at prospective franchisees are submitted to the regulator before use.

This rule matters for franchise websites and lead generation pages. A page that solicits franchise buyers can count as franchise advertising.

How is a franchise registered in a registration state?

A franchise is registered by filing an application package with the state regulator. The package contains the FDD with state-specific addenda, the application form, the franchisor’s audited financial statements and the filing fee. Eight states accept or require filing through NASAA’s Electronic Filing Depository; New York and North Dakota require it, with an EFD processing fee of $100 for initial filings and $50 for renewals, according to Franchise Law Solutions.

After approval, the franchisor tracks each state’s renewal date. A lapsed registration stops sales in that state until it is renewed.

Does federal law apply in states without franchise registration?

Federal law applies in every state. In states with no franchise registration or filing law, the FTC Franchise Rule still requires the franchisor to provide the FDD at least 14 calendar days before the prospect signs a binding agreement or pays any money. The FTC’s FDD disclosure requirements are the national floor.

Franchisors planning their first year of sales usually start in non-registration states and add registration states as the system grows. That sequence is one of the decisions covered in the franchise development steps.

Frequently asked questions

How many franchise registration states are there?

Thirteen states require franchise registration according to 2026 franchise law sources: California, Hawaii, Illinois, Indiana, Maryland, Michigan, Minnesota, New York, North Dakota, Rhode Island, Virginia, Washington and Wisconsin. Lists showing 14 include South Dakota, which current sources classify as an annual notice filing state.

Can I sell franchises in a non-registration state without an FDD?

No. The FTC Franchise Rule applies in every state, so a franchisor must give the FDD at least 14 calendar days before a prospect signs a binding agreement or pays any money, even where no state registration exists.

What does it cost to register a franchise in California?

California's initial franchise registration fee is $1,865 according to 2026 sources, the highest of the registration states. Attorney fees for preparing the application are separate.

Do I need to register if I only advertise online?

Online franchise advertising can reach residents of registration states. Franchisors that are not registered in a state commonly add disclaimers to franchise ads and screen out prospects from that state. The exact rules differ by state, so confirm the approach with a franchise attorney.

Related guides

Sources

  1. Franchise Law Solutions, The Franchise Registration States (2026)
  2. Franchise Law Solutions, FDD Registration Guide (2026)
  3. LegalClarity, Franchise Registration States: Laws, Fees, and Exemptions
  4. FTC, Franchise Rule Compliance Guide

This guide is general information, not legal, tax or investment advice. Franchise laws change and apply differently to each business. Review any franchise decision with a franchise attorney and an accountant.