Franchise Disclosure Register penalties: what five infringement notices teach

• The annual deadline is on or before the 14th day of the fifth month after your financial year ends: 14 November for a 30 June year end, 14 May for a 31 December year end.
• Redaction is a penalty provision too: remove personal and franchisee-specific information before uploading your standard agreement or logo (s94).
• An infringement notice is 60 penalty units for a company, $21,840 at the value from 1 July 2026, and paying one isn't an admission.
• The June 2025 notices were the ACCC's first for failing to annually update or confirm Register information, according to its 2024–25 annual report.
• The ACCC has kept the Register since 21 October 2025, as well as enforcing it.

1. Cash Converters Pty Ltd, June 2025: paid $16,500 after the ACCC alleged it failed to meet its obligation to annually update or confirm its Register information. Lesson: the confirmation is due even when nothing has changed (s93(2)(a)).
2. Mobile Travel Agents, June 2025: paid $16,500 over the same alleged failure. The ACCC said accurate, up-to-date profiles help prospective franchisees decide whether to enter into an agreement.
3. HN Macgregor Franchisor Pty Ltd, a Harvey Norman franchisor, August 2025: paid $15,650 after the ACCC alleged mandatory information was missing from the Register before it entered into a franchise agreement in July 2024. Lesson: the pre-signing duty covers every required field, not just a basic listing.
4. Luxottica Franchising Australia, franchisor of OPSM and Laubman & Pank, March 2026: paid $19,800 after the ACCC alleged its profile was out of date; it acknowledged it had failed to update the Register by May 2025 as required. Lesson: a May deadline applies to a 31 December year end, so don't assume 14 November.
5. Venue Smart Pty Ltd, August 2026: paid $59,400 across three notices under the 2024 Code, one alleging it failed to provide the required Register information at least 14 days before entering into a franchise agreement. The other two concerned its marketing fund. Lesson: Register gaps often sit beside other compliance gaps.

Paying a notice isn't an admission. Under the Competition and Consumer Act, a person who pays an infringement notice isn't, merely because of the payment, regarded as having contravened the provision.

• First registration (s92): before entering into a franchise agreement that needs a disclosure document, provide the required information at least 14 days before signing, in the ACCC's approved form and manner. It applies if you haven't registered before, including under the old Code's clauses 53C and 53D, and to a master franchisor only where there are 2 or more subfranchisors.
• Required information: name, business name, ABN, addresses, phone, email and ANZSIC industry codes (s92(2)), plus the extra information in the Additional Information Determination 2022, such as outlet numbers, costs, supply restrictions, agreement terms and the integrity questions.
• Annual update (s93): at least once for each financial year, confirm information that is still correct, and provide or update anything incorrect, out of date or missing.
• Redaction (s94): before uploading your standard form agreement or logo, or a link to them, remove personal information about other individuals and details of particular franchisees or sites. You may also redact commercially sensitive information.
• Agents (s95): a lawyer or consultant can lodge for you, but the obligation, and the penalty risk, stays with the franchisor.
• Each of s92(2), s93(2) and s94(2) carries up to 600 penalty units per contravention.

Section 93(3) sets the annual deadline: on or before the 14th day of the fifth month after your financial year ends. The ACCC's Register page says 'before' the 14th, so aim to lodge a few days early.

• 30 June year end: on or before 14 November. Next: 14 November 2026, for 2025–26.
• 31 December year end: on or before 14 May. Next: 14 May 2027, for the 2026 calendar year.
• 31 March year end: on or before 14 August. Next: 14 August 2027, for 2026–27.
• 30 September year end: on or before 14 February. Next: 14 February 2027, for the year to 30 September 2026.
• First registration: at least 14 days before signing. To sign on 30 October 2026, lodge no later than 15 October 2026 to be safe.
• Removal risk: information not updated, replaced or confirmed for 18 months can be removed (s91(3)). A profile last updated on 1 March 2025 and left untouched could be removed from 1 September 2026.

• No one owns the deadline, or it is diarised against the wrong financial year end.
• The Register confirmation is confused with the disclosure document update, which falls due earlier: 31 October for a 30 June year end.
• A franchisor lists its basic details but not the extra information before its first sale.
• A new franchisor entity or brand signs its first agreement before its own profile is lodged.
• Outlet numbers, costs, states or agreement terms change, but the profile doesn't.
• An agent lodges late or incompletely, and no one checks.
• The person who holds the Register login leaves the business.

• 60 penalty units for a company: $21,840 at $364 a unit from 1 July 2026, or $19,800 at the previous $330 value, the amount Luxottica paid in March 2026.
• 12 penalty units for an individual: $4,368 at today's value.
• The ACCC must issue a notice within 12 months of the alleged contravention. You have 28 days to pay, and the ACCC can extend that once, by up to 28 days.
• Paying isn't an admission, and it stops Commonwealth proceedings for that alleged contravention. Not paying leaves you open to court action, where the maximum is 600 penalty units.
• Paid notices are public: the ACCC announced all five Register cases by media release, and it lists paid notices on its infringement notices register.
• Paying doesn't fix the problem. You still need to lodge the missing or corrected information.

• Name a Register owner and a backup, and record your financial year end in writing.
• Diarise the annual deadline, with reminders 30 days and 7 days before.
• Confirm the profile every year, even if nothing has changed.
• For any new franchisor entity or brand, lodge the full profile at least 14 days before its first agreement.
• Reconcile the profile with your disclosure document at each annual update.
• Redact personal and franchisee-specific details before uploading documents.
• Keep a copy of every lodgement and its date.
• If you miss a deadline, lodge straight away and get legal advice.