New York Franchise Law & FDD Registration

The New York Attorney General’s Investor Protection Bureau enforces the Franchise Sales Act and oversees FDD registrations, renewals, and amendments.

Typical filings include: Uniform Franchise Registration Application, cost and source of funds forms, audited financials, sales agent disclosures, and the FDD itself. All filings are electronic through the NASAA online FDD filing portal. 

• $750 initial registration fee (+ $100 electronic filing fee)
• $150 annual renewal fee (+ $50 service fee)
• $150 amendment fee (as applicable)

Audited financial statements are mandatory. Start-ups must include an audited opening balance sheet. Renewals require three years of audited statements.

Typically 8–16 weeks, depending on completeness of filings,responsiveness to examiner comments, and time of year when the application is filed.

New York recognizes limited exemptions (isolated sale, existing franchisee, net worth). These are narrow and still require FDD disclosure.

This exemption applies if a single franchise is offered to no more than two people, without public advertising or prior sales, and only once. It's a narrow exemption from registration—not from disclosure—and is self-regulated, meaning you must ensure all conditions are met.

A franchisor is exempt from FDD registration if:

• It has a net worth of $15 million or more; or
• It has a net worth of $3 million and is at least 80% owned by a company with a $15 million net worth.

This exemption does not relieve FDD disclosure obligations.

General internet offers may qualify under “safe harbor” disclaimers, but targeted ads or directed communications usually trigger registration obligations.

You must renew your registration annually, no later than 120 days after the end of your fiscal year. 

You must file an amendment if there are material changes in your franchise system, financials, operations, or any facts that would render the current FDD misleading prior to your next renewal.