2026 is well underway, and upon the occurrence of a calendar year-end, franchisors should be considering if annual updates to their Canadian franchise disclosure document (FDD) are required.
Importantly, if your franchisor entity has a fiscal year end, like many do, on or around December 31 (i.e., December 31, 2025), then you are required to update your FDD by replacing the financial statements for the most recently completed fiscal year by no later than the end of June 2026 (within 180 days of the fiscal year end, at the very latest), or you cannot use the FDD at all after this date.
In addition, in 2026 we will see the introduction of a new franchise law, the first one in the province of Saskatchewan, called The Franchise Disclosure Act. This new franchise law comes into force on June 30, 2026, and necessitates updates to your Canadian FDD in order for it to comply with Saskatchewan’s requirements, and if you want to have one Canadian FDD usable throughout the country.
If you plan to offer franchises in any of the seven Canadian provinces requiring disclosure or will have renewals or resales forthcoming in those provinces, you need to ensure that your FDD complies with the requirements of each applicable provincial franchise law, and that the contents of your FDD are consistently accurate and up-to-date. That includes updating of all prescribed disclosure items and ensuring the FDD always includes all material facts.
A relatively small amount of effort by counsel and the franchisor can yield a form of FDD that can greatly minimize your risk of a claim based on non-compliance. Please feel free to reach out to any member of our Franchise Law Group for assistance.