Notice Filing States
Some U.S. states do not require full state-level registration of a franchise offering. Instead, they require franchisors to submit a notice, exemption filing, or business-opportunity filing before offering or selling franchises. These states are commonly called Filing States or Notice Filing States.
A notice filing does not mean the state endorses or certifies the franchise. It simply provides the state with required disclosure and business-opportunity information.
Filing Requirements: One-Time vs Annual
One-Time Filing States
In these states, franchisors are required to submit a single filing (or exemption notice) before making an offer or sale. After that and submission of required documents and fees, no further filings are required unless the law changes.
Annual Filing States
These states require franchisors to file (or renew) their disclosure or business-opportunity filing each year. Failing to file annually can result in compliance violations and impact your ability to legally offer franchises in that state.
How Notice Filing Works
Even in filing-only states, you should maintain a full, FTC-compliant Franchise Disclosure Document ready for prospective franchisees.
Provide required state-level disclosure forms, attach a copy of the FDD (or summary), and pay the filing fee.
Many states allow online filing; others may require secure upload, mail, or other submission methods.
For annual-filing states, maintain records and calendar renewal deadlines. For one-time states, keep submission confirmation on file.
Because no state “approves” the franchise, compliance depends on the accuracy and truthfulness of your disclosures and adherence to renewal obligations.
Current Notice Filing States
Annual Filing States
- Florida
- Utah
One-Time Filing States
- Connecticut
- Kentucky
- Nebraska
- Texas
Because state laws can change, always check the latest requirements before offering or selling franchises. For a full state-by-state analysis, see our Franchise Laws by State guide.
Why Proper Filing Matters
Filing — even when only a notice is required — ensures you meet state regulatory obligations. It does not mean the state endorses or certifies the franchise. Using misleading language like “state approved” can expose franchisors to regulatory risk and legal liability.
How Experienced Counsel Supports Compliance
A knowledgeable franchise attorney can:
- Confirm which states require filing, registration, or neither
- Prepare and submit the correct forms or exemption filings
- Track annual renewal deadlines and ensure timely compliance
- Advise on permissible communications and avoid misleading claims
Need Help With Notice Filing Compliance?
Waldrop and Colvin guides franchisors through the notice-filing process and ensures filing or renewal obligations are satisfied. We also assist prospective franchisees in confirming compliance before making an investment.
Contact Derek Colvin for assistance with franchise filing state compliance or FDD review.
