March 18, 2025 Copyright ©️ 2025 by goldkeen International Patent & Trademark Joint Office
1. Europe
- No unified franchise law, but pre-contractual disclosure is required in many countries.
- France, Spain, the Netherlands, Belgium, Romania, and Sweden require disclosure by law.
- Germany lacks specific disclosure rules, but the Civil Code requires good faith and full disclosure during negotiations.
- Italy has enacted franchise-specific disclosure legislation in recent years.
2. Australia
- Has comprehensive franchise regulations, including a mandatory Franchise Code of Conduct.
- Franchisors must provide a disclosure document at least 14 days before contract signing.
- The code also governs marketing funds, cooling-off periods, contract termination, and dispute resolution via mediation.
3. New Zealand
- No dedicated franchise law; franchises are governed under general commercial law.
- However, the Franchise Association of New Zealand (FANZ) maintains a self-regulatory code of conduct for its members.
4. United States
- Franchise regulation is highly stringent.
- Franchisors must disclose a Franchise Disclosure Document (FDD) containing 23 detailed sections about their business.
5. Canada
- Recent legislation enhances disclosure and fairness toward franchisees.
- Franchisees are granted rights such as forming associations and initiating collective actions.
6. China
- Over 400,000 franchised outlets nationwide.
- Franchisors must be registered with regulatory authorities and must:
- Have operated at least two company-owned outlets for over a year;
- Maintain a clean business record;
- Provide long-term operational guidance and training;
- Offer a 3-year standard franchise contract, operations manual, and working capital plan.
7. India
- Franchise agreements are governed by the Indian Contract Act and Specific Relief Act, which provide enforceability and remedies.
8. Russia
- Franchisors cannot impose pricing restrictions on franchisees.
9. Kazakhstan
- Has dedicated franchise legislation, encouraging foreign investors by protecting intellectual property rights.
10. Lithuania
- Defines franchise agreements as contracts between a “rights holder” and a “user”.
11. Brazil
- Under the Brazilian Franchise Law, franchisors must provide a disclosure document covering brand, trademarks, technology, etc., in exchange for franchise fees.
12. South Korea
- Laws require franchisors to support, educate, and assist franchisees in running the business.
13. Malaysia
- Franchisors are legally required to provide materials, training, and marketing support to franchisees.
Note: This information is translated and summarized from [franchisense.org]. Local legal and regulatory conditions should be verified before entry into each market.
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