⚡ Maryland’s New Franchise “Fast-Track” Renewal Program: A Head Start for Smart Franchisors

If you offer franchises in Maryland, there’s good news: the state has launched a Fast-Track Review Pilot Program that lets eligible franchisors renew their Franchise Disclosure Document (FDD) registration early—and get cleared before the springtime review crunch hits.

For franchisors, this isn’t just a regulatory tweak—it’s a competitive advantage.

✅ Earlier approvals mean you can start offering and selling sooner.
✅ Fewer review delays mean cleaner compliance and better predictability.
✅ No extra cost means you can gain all of the above with the same $250 renewal fee.

But there is a catch – you have to plan ahead and move quickly.  At Waldrop & Colvin, we help franchisors use opportunities like this to build momentum, not lose it to paperwork.

💡 Why Maryland Created the Fast-Track Program

Each year, the Maryland Securities Division faces an avalanche of renewal filings from March through May—precisely when most franchisors finalize audited financials.

In 2025, more than 79 percent of filings hit during that three-month window; in 2024, it was 65 percent. The result? Longer reviews and registration gaps that can stall franchise sales.

The Fast-Track Program encourages franchisors to file by February 1. In return, the state promises an expedited review so renewal registrations can be approved before the usual April rush.

Think of it as a priority lane for organized franchisors—an incentive for those who plan ahead.

⚖️ Who Qualifies (and Who Doesn’t)

To participate, your franchise system must check a few boxes:

👉 Our legal team can work with you to determine whether you qualify, update your disclosure document, and help you prepare your application correctly the first time.

🗓️ Key Filing Deadlines (Simplified)

If you miss a deadline, your file simply shifts to the regular renewal queue—no penalty, just slower review.

🧩 What to Submit

To qualify for the February 1 window, you’ll need to prepare:

1. 📄 Cover letter electing to join the Fast-Track Program

2. 🧾 Renewal application forms (minus Form F and the Certification section of Form A)

3. 📘 Clean FDD

4. 🖋️ Blacklined (aka Redlined) FDD showing all edits from the last registered version

5. 💵 $250 renewal fee

Then, by April 10, submit:

• ✅ The Completed Renewal FDD (now including your audit)

• ✅ Marked Pages showing updates since the February filing

• ✅ Consent of Accountant (Form F)

• ✅ Certification (Form A)

💡 Leave the issuance date blank on your February 1 filing—it’s filled in later with the completed renewal. 

🧮 What Counts as “Material Change”?

Maryland wants the Fast-Track Program to remain efficient. If you submit major mid-stream edits—say, a new franchise fee structure or rewritten Item 19 earnings claim—the Division can remove your file from Fast-Track status.

Examples of “significant material changes” include:

• whether the franchisor could have anticipated the change(s) before initially submitting the renewal FDD; 

• the substantive nature of the changes and/or whether the changes may fundamentally alter the franchise offering;

• whether the changes warrant enhanced disclosure;

• the number of changes made;

• other factors that may be considered relevant at the discretion of the Securities Division.

Waldrop & Colvin can help you evaluate whether your updates cross that line before filing, so you can make informed decisions. 

🔍 How the Program Helps Franchisors

✅ 1. Sell Earlier in the Year

If your renewal clears in April instead of July, you can start offering sooner—right when spring franchise expos and Discovery Days ramp up.

✅ 2. Avoid the Spring Bottleneck

Late filings often get stuck behind hundreds of others. Fast-Track lets you skip the line.

✅ 3. Reduce Legal Risk

Early examiner feedback means fewer last-minute surprises and a lower chance of lapses in registration.

✅ 4. Maintain Multi-State Momentum

Aligning Maryland’s earlier timeline with other registration states helps you roll out updated FDDs consistently nationwide.

✅ 5. Show You’re a “Prepared Franchisor”

Regulators notice when filings arrive on time and in perfect order. It builds credibility—and helps future renewals move faster.

🧠 Common Client Questions

Q: Does Fast-Track cost more?
No—just the standard $250 renewal fee.

Q: What if our audited financials aren’t ready by Feb 1?
That’s fine. File the draft FDD and note in your cover letter that audited financials will follow by Apr 10.

Q: Can we amend last year’s FDD while Fast-Track is pending?
Yes. File a post-effective amendment through NASAA’s FRED portal or by mail with a $100 fee—and mirror those updates in your Fast-Track submission.

Q: Are we allowed to keep selling franchises while waiting?
It depends – your attorney needs to conduct a materiality analysis to ensure last year’s registered FDD is still accurate. If major changes occurred, you may need to pause offers until the new permit is issued and/or make updates and file a post-effective amendment to the prior years registration. 

⚙️ The Compliance Framework Behind It

The program is rooted in Maryland’s Franchise Registration and Disclosure Law (Md. Code Ann., Bus. Reg. §14-201 et seq.), particularly §14-219 on renewals.

Even with faster processing, the same legal obligations apply:

It remains unlawful to omit or misstate any material fact in a registration or renewal filing (§14-231).

That means accuracy and transparency still rule the day—Fast-Track simply gives compliant franchisors a way to move faster without cutting corners.

🧭 Strategic Planning Tips from Waldrop & Colvin

🗂️ 1. Begin Audit Prep Early

Ask your CPA to prioritize your audit for March delivery. Missing the April 10 window forfeits Fast-Track eligibility.

🧾 2. Keep FDD Version Control Tight

Every edit must appear cleanly in the blackline. Disorganized FDD management is the fastest way to invite deficiency comments.

🧩 3. Coordinate Across States

File your Maryland Fast-Track renewal alongside early filings to streamline multi-state compliance.

🔔 4. Communicate with Examiners

If Maryland issues deficiency comments, respond promptly and completely. Silence can remove you from Fast-Track status.

🤝 5. Lean on Your Counsel

Our team manages the entire renewal process—from drafting the cover letter to responding to examiner comments—so you can focus on franchise growth, not redlines.

🌐 Real-World Impact: Why Timing Matters

Imagine two franchisors with identical systems:

That’s a four-month head start on new franchise awards—without any extra cost. For growing systems, that’s the difference between missing or hitting an annual development goal.

🏁 Final Takeaway

Maryland’s new Fast-Track Franchise Renewal Program rewards organized franchisors with early clearance, faster sales cycles, and fewer headaches.

It’s not a shortcut—it’s a smarter way to manage compliance. And with state examiners watching closely to see how franchisors handle the pilot year, getting it right matters more than ever.

📞 How Waldrop & Colvin Can Help

Our firm assists franchisors nationwide with FDD drafting, renewals, registration strategy, and multi-state coordination.

For Maryland filings, we can:

• Update your current FDD and determine eligibility for Fast-Track,

• Prepare the complete filing package (clean + blackline FDD, forms, and cover letter),

• Handle examiner responses and deadline tracking, and

• Ensure your FDD updates align with other state submissions.

From registration strategy to FDD compliance and franchise system structuring, our attorneys blend legal precision with real-world growth insight.