FDD Item 19 Statistics: How Many Franchisors Disclose Earnings, and What They Include

Education and children's brands disclosed most often at 94.4%, while lodging sat at 44.4%. Each sector rests on a small number of FDDs, so one brand can move a rate by several points. Read the gaps as directional.

Revenue shows up almost everywhere at 94.5%. Only 33.5% of Item 19s go below gross profit to something like EBITDA or net income, which is closer to what you would take home.

The smallest systems, with 0 to 9 franchised outlets, disclosed least at 66.1%. A young brand may simply have too little history, which is worth asking about directly.

In 40.0% of Item 19s, the figures cover 90% to 100% of outlets. In 9.0%, fewer than half the outlets are counted, so the average can describe a select group.

Nearly every Item 19 warns that your results may differ (99.0%). Fewer state whether the numbers were audited, and only 31.0% list outlets one by one.

Item 19 disclosure by sector, FDDs issued 2025 to 2026 (Minnesota registrations)

Source: Franchise Consultants and Brokers (data from Minnesota Department of Commerce CARDS filings), Franchise Item 19 Disclosure: What 259 FDDs Report and Leave Out (2025 to 2026). Download as image

Deepest measure reached in each Item 19, FDDs issued 2025 to 2026

Source: Franchise Consultants and Brokers (data from Minnesota Department of Commerce CARDS filings), Franchise Item 19 Disclosure: What 259 FDDs Report and Leave Out (2025 to 2026). Download as image

Whose outlets Item 19s describe and which outlets they leave out, FDDs issued 2025 to 2026

Source: Franchise Consultants and Brokers (data from Minnesota Department of Commerce CARDS filings), Franchise Item 19 Disclosure: What 259 FDDs Report and Leave Out (2025 to 2026). Download as image

Published estimates of Item 19 prevalence and content, each as its source states it

Source: FRANdata for the IFA Franchise Education and Research Foundation, Financial Performance Representation: Market Demand Pushing Higher Levels of Transparency; Franchise Update Media, Looking at What is in a Franchise's FDD (2026 Annual Franchise Development Report summary); Franchise Consultants and Brokers (data from Minnesota Department of Commerce CARDS filings), Franchise Item 19 Disclosure: What 259 FDDs Report and Leave Out (2025 to 2026). Download as image

What is Item 19 in an FDD?

The FTC Franchise Rule requires a franchisor to hand you its FDD before you sign or pay. Item 19 covers financial performance representations: any statement about the sales, income or profit of existing or likely outlets.

Two things make Item 19 unusual. First, it is voluntary. A franchisor that does not want to give figures prints a prescribed no-representation statement instead, and 22.8% of the FDDs in the study did exactly that. Second, if a franchisor does make earnings claims, they are supposed to live in Item 19 and nowhere else. A salesperson who shows you a spreadsheet of owner profits that does not appear in Item 19 is a warning sign.

Whatever the franchisor puts in Item 19 must have a reasonable basis, and 97.0% of the Item 19s studied offered written substantiation on request. You are allowed to ask for it. Do.

How many franchisors disclose Item 19?

In the 2025 to 2026 sample, 77.2% of FDDs included an Item 19, with a 95% interval of 71.7% to 81.9%. That is a large share, though the sample drew a set quota of FDDs per sector, so it is not weighted to all franchisors.

Older data points the same way. FRANdata, working for the IFA Foundation, found that two-thirds of more than 3,000 brands gave a financial performance representation in FDDs from 2014 to 2016. A 2026 Franchise Update Media survey had 84% of franchisors saying they provide one, but that is a self-reported answer from franchise development staff, not a count of filed documents.

Sector matters more than the overall rate suggests. Retail disclosed at 55.6% and lodging at 44.4%, well under the 94.4% for education and children's brands. If you are shopping in a sector where silence is common, a missing Item 19 is less unusual. It still means you have to build the numbers yourself.

Does Item 19 show franchise profit?

Usually not. Of the 200 Item 19s, 94.5% reported gross sales, net sales or revenue, and 74.5% gave a per-outlet average or median sales figure. Only 42.5% showed any profit-type line, and that includes gross profit. Just 33.5% went further down to EBITDA, operating income or net income.

Put another way, 101 of the 200 Item 19s, or 50.5%, stopped at revenue. A unit that does high sales can still lose money once rent, payroll, royalties and marketing fees come out. A strong average sales figure, on its own, tells you nothing about whether a typical owner clears enough to repay a loan.

This is not new. In the 2014 to 2016 FRANdata work, 94% of brands with an Item 19 gave average unit revenues, 47% showed any operating expenses and 34% showed profitability. The broad pattern looks much the same today.

Which outlets are left out of the numbers?

An average is only as honest as the group it averages. The median Item 19 covered 85.5% of outlets, measured across the 192 where coverage could be worked out. That leaves a slice of the system outside the figures in most documents.

The common exclusions are easy to miss. 80.5% of Item 19s left out outlets open less than a minimum time. 45.5% dropped closed or transferred outlets, which are often the weakest performers. 39.5% counted only outlets that reported data, and 34.0% looked at a single format or outlet type. Each of these can be reasonable on its own. Stacked together, they can make the average describe the survivors rather than the system.

Also check whose outlets you are looking at. In 9.0% of Item 19s, the figures came from company or affiliate outlets only. Those locations may have better sites, bigger budgets and no royalty to pay, so they are a weak stand-in for a franchisee's results.

What the numbers mean if you are buying a franchise

Start by sorting the brands on your list into three groups: no Item 19, revenue only, and revenue with costs or profit. That simple sort tells you how much homework each one leaves you. A brand in the third group has done part of the work. A brand in the first has left all of it to you.

For a revenue-only Item 19, your job is to build the missing half. Ask the franchisor for typical occupancy and labor costs, then test those against what owners tell you. Lenders will do the same math, so you may as well do it first and walk in with a budget you believe.

Size matters too. Smaller systems disclose less often, and when they do, the figures may rest on a handful of outlets, sometimes company-run ones. Ask how many units sit behind each number and how long they have been open. A median drawn from mature outlets in strong markets is a ceiling for a new owner, not a forecast.

Finally, remember the agreement does not care what Item 19 said. Your royalty, ad fund contribution and lease payment are due in a slow month just as in a strong one.

How to read an Item 19 before you sign

• Find the base. Note how many outlets the figures cover and compare it to the total in Item 20. A big gap needs an explanation.
• Look for the median, not just the average. 83.0% of Item 19s report a median; a few strong units can drag an average up.
• Check how many outlets met or beat the average. 72.0% of Item 19s say so. If yours does not, ask.
• Ask whether the figures are audited. 57.0% state that they are unaudited, which is common but worth knowing.
• Build your own profit picture. Start from the revenue figure and subtract royalties and ad fees from the FDD's fee disclosures, then your rent, payroll and loan payments.
• Call current and former franchisees from the Item 20 list and ask what they actually net. Their answers are the best check on Item 19.
• Request the written substantiation. If the franchisor will not provide it, treat the numbers with care.

Sources and method

Every number on this page comes from the sources below, each opened and read on or before October 18, 2026. A second, independent review checked every figure against its source and corrected anything that did not match. Figures that could not be confirmed were left out.

1. Franchise Consultants and Brokers (data from Minnesota Department of Commerce CARDS filings), Franchise Item 19 Disclosure: What 259 FDDs Report and Leave Out (2025 to 2026) (Updated October 6, 2026 (first release))
2. FRANdata for the IFA Franchise Education and Research Foundation, Financial Performance Representation: Market Demand Pushing Higher Levels of Transparency (April 2017)
3. Franchise Update Media, Looking at What is in a Franchise's FDD (2026 Annual Franchise Development Report summary) (July 14, 2026)