It has been nearly a decade since a new Canadian province enacted franchise legislation, but Saskatchewan is set to change that in 2026. Its new franchise disclosure regime comes into force on June 30, 2026, and franchisors will need to make changes to their disclosure documents and compliance practices.
Background
In April 2025, the Government of Saskatchewan released draft regulations under its newly enacted The Franchise Disclosure Act (the Act),1 marking the province’s entry into legislated franchise disclosure requirements. As highlighted in an earlier Cassels Comment, the initial draft of the Act signaled Saskatchewan’s intent to align its regime with those already established in the six other Canadian provinces that already had adopted franchise legislation (the Regulated Provinces),2 while leaving several key areas open to clarification.
Recent amendments have now addressed many of those uncertainties and confirmed that the Act will come into force on June 30, 2026. Saskatchewan’s shift to a statutory disclosure model represents a significant development in Canadian franchise law, increasing compliance obligations for franchisors operating in multiple jurisdictions.
Key Legislative Features and Clarifications
Together, the Act and The Franchise Disclosure Amendment Regulations, 2025 (the Regulations) provide the foundation for Saskatchewan’s new disclosure regime.3
- New Definitions: The Regulations introduce definitions for previously undefined but critical terms, including “officer,” “earning projection,” and “foreign jurisdiction.” These additions provide clearer guidance on which individuals are captured by disclosure obligations and when financial performance information crosses the line into regulated disclosure territory, giving franchisors more certainty when preparing their franchise disclosure documents (FDDs) and internal compliance frameworks.
- Definition of “Franchise”: The Act adopts a more narrow definition of “franchise” compared to Ontario’s Arthur Wishart Act, while remaining consistent with other Regulated Provinces such as British Columbia and Manitoba. Under the Act, a franchise relationship exists only where a payment is required and “the franchise or the franchisor’s associate exercises significant control over, or provides significant assistance in” the franchised business. By contrast, the Arthur Wishart Act applies even where the franchisor merely holds the right to exercise such control or provide assistance, regardless of whether that right is exercised.
- Financial Statement Flexibility: The Regulations also confirm that financial statements prepared in accordance with US GAAP audit or review standards are acceptable. This follows the recent amendments to the Arthur Wishart Act in Ontario. Ideally, all provinces will eventually allow for US GAAP audit or review engagement standards.
- Substantial Compliance Standard: The Act adopts a substantial compliance approach, meaning minor technical errors or omissions should not, on their own, invalidate a disclosure document that otherwise meets the Act’s purpose. This balances franchisee protection with practical compliance expectations for franchisors.
How to Prepare for June 2026
With the regulatory framework now largely finalized, franchisors can begin preparing for implementation. The June 30, 2026, implementation date provides a clear compliance window that aligns with most fiscal year-end planning and annual disclosure update cycles. This extended lead time supports a smooth transition and minimizes business disruption once the Act is in force. The Cassels Franchise Group is preparing a list of all updates required to comply with the new Saskatchewan Franchise Legislation.
How Franchisors Can Use This Time
- Integrate Saskatchewan-specific requirements into their annual disclosure document documents.
- Conduct internal legal and compliance reviews.
- Train relevant personnel and update internal systems and processes.
Practical Compliance Steps
As the deadline approaches, franchisors should now focus on meeting Saskatchewan’s specific statutory obligations under the Act. Taking these foregoing proactive steps will help franchisors avoid compliance pitfalls and ensure a seamless transition to the new regime.
What Comes Next?
While the Saskatchewan franchise legislation aligns closely with the Regulated Provinces, its distinct elements require customization of FDDs for use across Canada. Taking these steps early will help franchisors mitigate risk, ensure compliance readiness, and position themselves for a smooth transition when the new legislation comes into force.
At Cassels, our Franchise Law Group is well positioned to guide franchisors through the transition to Saskatchewan’s new disclosure regime. Please contact a member of our Franchise Law Group to learn how we can assist in developing a tailored compliance strategy in advance of the June 2026 implementation date.
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1 The Franchise Disclosure Act, SS 2024, c 13.
2 The six “Regulated Provinces” with existing franchise disclosure legislation are Alberta, British Columbia, Manitoba, New Brunswick, Ontario and Prince Edward Island.
3 The Franchise Disclosure Amendment Regulations, 2025, Sask Reg 84/2025.