# Registration states

The [FTC Franchise Rule](https://www.ftc.gov/legal-library/browse/rules/franchise-rule) is federal. It requires a franchisor to prepare an FDD in a prescribed format and to furnish it at least fourteen calendar days before a binding agreement with, or payment to, the franchisor or an affiliate. It does not require the franchisor to file that FDD with the Commission. Most of the country is disclosure-only at the federal level.

A group of states add their own franchise statutes. In those states a franchisor generally must register the offering, or make a notice filing, before offering or selling in the state, on that state's definitions of "offer," "sale," and whose residents count. The statutes are not identical. Michigan, for example, is often handled as a notice filing rather than a full merit review. Counsel, not a comparison table on a website, decides which regime applies to a particular buyer and site.

This page is a field method for using public files. It is not a complete state-by-state opinion.

## What a registration file is good for

A state file lets a buyer:

- confirm that an offering is currently registered or noticed in that state;
- match legal franchisor name, issue date and, sometimes, effective date to the PDF in hand;
- see amendments;
- in some states, download or inspect the FDD that was filed.

It does not certify unit economics. It does not replace Item 23. It does not start or stop the federal fourteen-day clock, though some states add their own waiting-period or first-personal-meeting rules on top.

The cover of every FDD, under [16 CFR 436.5](https://www.law.cornell.edu/cfr/text/16/436.5), already says that no government agency has verified the information. A Wisconsin stamp does not contradict that sentence.

## Two public desks this guide already uses

**Wisconsin.** The Department of Financial Institutions maintains a public [franchise search](https://apps.dfi.wi.gov/apps/FranchiseSearch/). GDK's [2025 Wisconsin filing](https://apps.dfi.wi.gov/apps/FranchiseSearch/details.aspx?id=639752&hash=370187205&search=external&type=GENERAL) and The Halal Guys' [2025 Wisconsin filing](https://apps.dfi.wi.gov/apps/FranchiseSearch/details.aspx?id=639117&hash=921753141&search=external&type=GENERAL) are worked examples: they identify a document and an effective window in that state. Wisconsin re-registers annually rather than "renewing" a perpetual number; a gap with no sales can be ordinary. A buyer still wants the PDF that was furnished to them, not only the search-result metadata.

**Minnesota.** Shah's Halal Food's [2025 Minnesota-filed document](https://cards.web.commerce.state.mn.us/documents/%7B9078B29B-0000-C21E-982F-C2FDAFB07783%7D/download?contentSequence=0&documentClass=FRANCHISE_REGISTRATIONS) is a complete FDD a reader can open. Use it to practice Item 5–7, Item 19's "no representation" language, and Item 20's licensed-versus-franchised story (the 2024 FDD used in this set: 0 franchised, 44 licensed of 58 as of 2023). A Minnesota file is evidence of a Minnesota registration, not a nationwide "current everywhere" stamp.

If the buyer or the restaurant will be in one of those states, pull the search on the same day you timestamp FDD delivery. If they will not, the public file is still a comparison tool — and still not the delivered document for the transaction.

## FTC versus state, in one table

| Topic | FTC Franchise Rule | Registration / filing state |
| --- | --- | --- |
| Who must prepare an FDD | Franchisor offering in the US, with exemptions | Same federal duty, plus state statute |
| Must the FDD be filed federally? | No | Often yes, with that state's agency |
| Waiting period | 14 calendar days (and 7 on certain unilateral agreement changes) | May add earlier disclosure or extra waiting |
| Does acceptance equal approval of the investment? | No | No |
| Where a buyer checks | The PDF they were furnished, Item 23 | State search plus that same PDF |
| Doner Shack in this set | No current US registration as of 2026 | Nothing to pull |

Doner Shack is the negative example. This dataset records no current US offering. A glossy UK site does not create a Wisconsin file.

## A worked filing comparison

Open three public documents and write one line each:

1. GDK Wisconsin 2025: legal name, effective date, whether the issue date matches the FDD you would actually read for a deal.
2. Halal Guys Wisconsin 2025: same fields. Note that the [operator franchise page](https://franchise.thehalalguys.com/) is still not the filing.
3. Shah's Minnesota 2025: download, then check Item 19 (no FPR in the 2024 source used in this set) and Item 20's franchise count.

Then add a fourth line from a brand that is in this set but may not be in the state you searched. Pepper Lunch's May 2024 comparative record discloses 6 US units. Absence from a Wisconsin search on a given day could mean not registered there, registered under a slightly different legal name, lapsed, or not yet filed this year. Do not conclude "the brand does not exist." Conclude "I cannot see a current Wisconsin offering at this search." That sentence is useful.

Great Greek's FDD issued 17 August 2023 and Mad for Chicken's FDD issued 3 May 2024 are dated sources in this set. Their current registration status in a given state is a search, not a memory.

<div class="checklist" markdown="1">

Registration-state desk pass

- Identify whether the buyer, the entity, or the site sits in a registration or filing state. Have counsel confirm.
- Search the state's public database by legal franchisor name, not only by trade name.
- Match issue date, entity and any effective date to the furnished PDF.
- File a screenshot of the search result beside Item 23.
- Read state addenda in the FDD; they can modify termination, governing law or integration for that state's buyers.
- Do not treat a filing as a quality score or a substitute for Item 19.

</div>

The commonly discussed registration-and-filing group includes California, Hawaii, Illinois, Indiana, Maryland, Michigan, Minnesota, New York, North Dakota, Rhode Island, South Dakota, Virginia, Washington and Wisconsin, with important differences among them. Confirm the current list and the buyer's facts with counsel. This publication will not pretend that a static paragraph outruns a statute that legislatures amend.

## Related reading

- [The fourteen-day rule](/fourteen-day-rule/) — federal clock, with state extras
- [How to read an FDD](/how-to-read-an-fdd/) — what to do with the PDF you pulled
- [FDD vs franchise agreement](/fdd-vs-franchise-agreement/) — state addenda live in the contract package
- [Item 1, the franchisor](/item-1-the-franchisor/) — the legal name to search
- [Attorney and accountant](/attorney-and-accountant/) — who confirms which statute applies

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HTML: https://qsrfieldguide.com/registration-states/
