Is franchise Item 19 disclosure required?

No — Item 19 disclosure is completely voluntary under FTC franchise disclosure rules. Franchisors are not required to share any financial performance representations. The only rule is that if they do disclose, the information must be accurate and have a reasonable basis. This is why some of the largest and most recognizable franchise brands (Subway, Five Guys, Little Caesars) disclose nothing — they've made a strategic choice not to.

What does it mean if a franchise doesn't disclose Item 19?

Not disclosing Item 19 doesn't automatically mean the brand is unprofitable — but it does mean you can't verify revenue claims from your FDD. Some brands with strong unit economics choose not to disclose because they don't want competitors to see their data. Others avoid disclosure because their numbers aren't favorable. Without Item 19, you'll need to rely on franchisee validation calls and independent research. If a franchisor salesperson verbally quotes revenue figures but those numbers don't appear in Item 19, that information is legally unverified.

Which franchise category has the highest Item 19 disclosure rate?

Business Services, Senior Care, Staffing, and Health and Wellness franchises have 100% disclosure rates in our database. Home Services (94%), Automotive (93%), Fitness (93%), and Education (92%) are also highly transparent. Real Estate franchises have the lowest disclosure rate at just 17% — only 1 of 6 real estate franchise brands in our database discloses any Item 19 data.

What is the disclosure rate across all franchise brands?

In our database of 170 franchise brands, 148 (87%) disclose Item 19 financial performance data. The 22 brands that don't disclose represent some well-known names: Subway, Five Guys, Little Caesars, Keller Williams, RE/MAX, Kumon, and Servpro — all of which have large national systems but have chosen not to publish revenue data.

Can I negotiate to see Item 19 data if it's not in the FDD?

Franchisors cannot legally share financial performance data outside of Item 19 in the FDD — doing so would be an unauthorized FPR (Financial Performance Representation) and could expose them to legal liability. If a franchisor's Item 19 is blank, they genuinely cannot share unit-level revenue data with you directly. Your only legitimate options are: speaking with existing franchisees (franchisee contact info is in Item 20), reviewing Item 20 closure rates as a proxy for performance, and finding independent data sources.

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FDD Item 19 Disclosure by Brand

Which 170 franchises publish financial performance data — and what it means when they don't.

Updated April 2026 · 170 brands analyzed

The Disclosure Reality

Item 19 — the Financial Performance Representations section of the FDD — is entirely optional. Franchisors are not required to disclose any revenue data. In our database of 170 franchise brands, 148 (87%) include Item 19 data, and 22 brands (13%) leave it blank.

The brands that don't disclose aren't necessarily performing poorly. Some of the most recognizable franchise names in the world — Subway, Five Guys, Little Caesars, Keller Williams, RE/MAX — have chosen not to publish revenue data. The reasons vary: competitive intelligence concerns, legal risk aversion, or simply that their unit economics vary too widely across their system to present a clean number.

What matters for your due diligence: if Item 19 is blank, no one from that franchise system can legally quote you revenue figures. Any verbal revenue claims made by a franchise development representative are legally unverifiable — and an FPR (Financial Performance Representation) made outside the FDD creates legal liability for the franchisor.

Disclosure Rate by Category

Disclosure patterns vary dramatically by industry category:

Category	Brands	Disclose Item 19
Business Services	6	6/6 (100%)
Senior Care	3	3/3 (100%)
Health and Wellness	1	1/1 (100%)
Staffing	1	1/1 (100%)
Home Services	31	29/31 (94%)
Automotive	14	13/14 (93%)
Fitness	14	13/14 (93%)
Education	12	11/12 (92%)
Personal Services	12	11/12 (92%)
Food	17	15/17 (88%)
Pet	8	7/8 (88%)
QSR	33	29/33 (88%)
Hospitality	6	4/6 (67%)
Retail	6	4/6 (67%)
Real Estate	6	1/6 (17%)

Real Estate stands out as the least transparent category. Only 1 of 6 real estate franchise brands in our database discloses Item 19. The likely reason: real estate agent revenue varies enormously based on local market conditions, individual agent effort, and years of experience — making a system-wide "average" potentially misleading and difficult to defend legally.

Brands That Don't Disclose Item 19

The 22 brands in our database that don't include Item 19 data span a range of sizes and categories. Notably, several of the largest franchise systems in the world are in this list:

Five Guys (QSR)
Taco Bell (Food)
European Wax Center (Personal Services)
Little Caesars (QSR)
Outdoor Collection by Marriott Bonvoy (Hospitality)
Ace Hardware Painting Services (Retail)
Circle K (Retail)
Bark Busters (Pet)
Berkshire Hathaway HomeServices (Real Estate)
Century 21 Real Estate (Real Estate)
Coldwell Banker Commercial (Real Estate)
Best Western (SureStay Collection) (Hospitality)
Kumon (Education)
Subway (QSR)
Weed Man (Home Services)
RE/MAX (Real Estate)
Servpro (Home Services)
Keller Williams Realty (Real Estate)
Schlotzsky's (Food)
Tint World (Automotive)
9Round (Fitness)
Jack in the Box (QSR)

What Subway's missing Item 19 means: Subway is the largest franchise system in the world by unit count (20,000+ US locations). Its absence from Item 19 disclosures means there is no FDD-verified revenue figure for a Subway franchise. Any revenue estimate you find online — including this site's — is derived from franchise broker estimates or franchisee interviews, not from a legal FDD disclosure.

How to Research Franchises That Skip Item 19

If a brand you're considering doesn't disclose Item 19, here's the due diligence path:

Item 20 franchisee contact list. Every FDD must include contact information for current and former franchisees. Call 10–15 of them. Ask: "What's your gross revenue in a typical year?" You'll get real numbers that way.
Item 20 closure rates. The number of franchisees who left the system (transferred, terminated, or not renewed) tells you about actual performance. High turnover is a proxy for poor economics.
Third-party broker data. Franchise brokers accumulate franchisee performance data across their client base. They have incentive to match you to a good fit — so ask them directly for revenue ranges.
SBA loan approval data. The SBA's loan database (accessible via FranData) shows which franchise brands get approved for SBA loans, which is correlated with franchisee financial performance.
Franchisee associations. Many brands have independent franchisee associations. These groups track system performance and can be a more candid source than the franchisor itself.

Why Same-Category Item 19 Comparisons Mislead

Comparing Item 19 revenue across brands in the same category seems logical but produces unreliable conclusions. The problem: each brand defines its reporting cohort differently. One QSR brand reports revenue for all units open 12+ months. Another reports only units open 24+ months. A third excludes units in "non-traditional" locations (airports, military bases, colleges) that often have different revenue profiles. The result: you're comparing numbers from fundamentally different populations. A brand reporting $900,000 median revenue for units open 24+ months looks better than one reporting $750,000 for units open 12+ months — but the second brand may actually have better unit economics because it includes younger, still-ramping units in its calculation. Before comparing Item 19 across brands: read the footnotes on each Item 19 to identify the cohort definition, the time period, and the exclusions. Normalize for cohort age (24-month cohorts always look better than 12-month cohorts). And check whether the revenue figure is gross revenue or net revenue after discounts and returns — some brands report gross, inflating the apparent performance by 5–10%.

The Missing Item 19 as a Negotiation Signal

When a franchise brand omits Item 19 entirely, most buyers treat it as a yellow flag and move on. Sophisticated buyers treat it as a negotiation lever. The franchisor knows that the absence of Item 19 makes the franchise harder to sell — SBA lenders scrutinize non-disclosing brands more carefully, and informed buyers demand more diligence time. This gives you leverage in three areas. First, the franchise fee: franchisors without Item 19 have fewer qualified leads and higher acquisition costs per franchisee, making them more willing to negotiate the initial fee ($5,000–$15,000 reductions are common). Second, territory protections: you can argue that without earnings data, you need a larger protected territory to reduce risk — and back it up by noting that lenders may require it. Third, royalty ramp-ups: instead of paying the full 6% royalty from day one, negotiate a graduated schedule (3% year one, 4.5% year two, full rate year three) citing the uncertainty that the missing Item 19 creates. The franchisor's alternative is losing you as a prospect entirely — and in systems where Item 19 is absent, qualified prospects are scarce.