Franchise Enforcement Actions: 562 State Orders, 2015 to 2026

Franchise enforcement actions by state and year

Washington and California publish most state franchise enforcement actions, and yearly volume has risen. The eight lists hold 562 franchise-law orders dated January 1, 2015 to October 14, 2026: Washington 230, California 150, Maryland 85, Minnesota 49, Virginia 27 (list starts in 2022), Wisconsin 12, South Dakota 5 (list starts in 2017) and Rhode Island 4.

Washington and California account for 67.6% of all orders, and the top three states for 82.7%. Part of that gap is publishing practice: Washington posts charges, consent orders and final orders, each with a summary (Washington DFI), while some registration states publish no order list at all (see coverage below).

In the five states whose lists cover every year (Washington, California, Maryland, Minnesota, Wisconsin), orders averaged 36 a year in 2015 to 2019 and 53.4 a year in 2021 to 2025, a rise of 48.3%. The single busiest year was 2021 (61 orders in those five states), when California issued 32 orders; 12 of those concerned franchise disclosure documents whose audited financial statements were signed by an auditor who was not licensed or qualified. Across all eight lists, 2025 had 71 orders, and 2026 had 40 by October 14.

What the orders charge: unregistered sales, disclosure and fraud

Three in four orders are about selling without registration; about one in three alleges a misrepresentation. Each order was coded for seven violation types from the statute sections it charges and the conduct it describes; one order can carry several.

• Unregistered offer or sale: 416 orders (74.0%).
• Disclosure document not delivered or not delivered 14 days ahead: 259 (46.1%).
• Defective disclosure document or registration filing: 150 (26.7%).
• Misrepresentation or omission in the offer or sale (anti-fraud sections): 172 (30.6%).
• Financial performance (earnings) representation: 53 (9.4%).
• Broker or seller violation: 49 (8.7%).
• Other (registration conditions, records, advertising filings, ignoring a regulator demand): 55 (9.8%).

363 orders (64.6%) charged registration or disclosure violations with no misrepresentation or earnings-claim count, and 260 (46.3%) charged nothing beyond an unregistered sale and a missing or late FDD. The mix differs by regulator: 67.3% of California orders concern a defective filing, against 13.5% in Washington, where 42.2% of orders include a misrepresentation or anti-fraud count. Minnesota’s orders are short and almost all describe an unregistered sale (98.0%), so its other categories are likely understated.

For comparison, GAO’s review of five states counted 196 franchise enforcement actions in 2019 to 2021, of which 59 alleged failure to provide an FDD and 72 alleged untrue or omitted material facts in FDDs (GAO-23-105338); that passage gives no count for unregistered sales. For complaint data and federal cases, see our franchise fraud report; a state order usually records a compliance breach, not proof of a scam.

Penalties, investigative costs and rescission offers

Penalties are usually small, and one state rarely fines at all. Of 457 resolving orders (consent orders, settlements and final orders), 215 (47.0%) imposed a fine or a civil, administrative or monetary penalty. The median was $5,000; the middle half ran from $2,000 to $12,000; 129 penalties (60.0%) were $5,000 or less and 13 were $50,000 or more. The largest, $450,000, was a California consent order in 2024. Penalties stated in resolving orders total $3,228,025 over almost 12 years; some were suspended, reduced or paid in instalments, so this is not an amount collected.

Practice varies by state. Minnesota fined in 97.9% of resolving orders (median $1,000); Virginia in 96.3% (median $6,250); California in 73.7% (median $7,500); Maryland in 63.9% (median $5,000). Washington imposed a penalty in only 4 of 184 resolving orders; instead it charged investigative costs in 130 orders, median $1,500.

Statutory ceilings are low in some states: a California DFPI citation can assess up to $2,500 per violation (Corp. Code 31406), Minnesota’s statute sets fines of up to $2,000 per violation (Minn. Stat. 80C.16), and Virginia’s Commission can impose up to $25,000 (Va. Code 13.1-570).

Rescission. 108 resolving orders (23.6%) ordered or recorded an offer to rescind, meaning the franchisor offers to unwind the sale and refund fees. Maryland did so in 69.4% of its resolving orders and Virginia in 55.6%; Washington in 1.6%.

Unregistered-sale cases

Selling without registration is the core of state franchise enforcement. 416 orders (74.0%) involved an offer or sale with no registration or exemption on file, including sales while an application was pending, after a registration lapsed, or under a contract the seller called a license. Of the 347 resolving orders in this group, 166 imposed a penalty (median $5,000) and 95 required or recorded a rescission offer.

Registration is required before any offer in each of these states, for example under Cal. Corp. Code 31110 and RCW 19.100.020. Which states require it, and at what fees, is covered in our franchise registration states tracker. Buyers who were sold an unregistered franchise can also sue: the statutes allow damages and, in some cases, rescission (Cal. Corp. Code 31300, RCW 19.100.190, Minn. Stat. 80C.17).

Earnings-claim cases

Earnings claims appear in about one order in ten, and almost always alongside a misrepresentation count. 53 orders (9.4%) involved a financial performance representation: 32 in Washington, 11 in Maryland, 9 in California and 1 in Virginia. 52 of the 53 were also coded as misrepresentation, because regulators charge unsupported or undisclosed earnings figures under their anti-fraud sections. Of 34 resolving orders in this group, 7 imposed a penalty (median $5,000).

Under the FTC Franchise Rule, a franchisor may give earnings figures if they have a reasonable basis and are included in Item 19 of the FDD, with narrow exceptions (16 CFR 436.5); our Item 19 report measures how often franchisors do. The orders here concern figures given outside Item 19, or an Item 19 that misstated or omitted material facts.

Repeat respondents across states

Some respondents recur across states. After normalising names (dropping corporate suffixes and matching trade names), 62 respondents appear in two or more separate matters, and 51 of them in orders from two or more states. One respondent appears in five states’ lists, and the most for one respondent is 6 separate matters. 154 of the 562 orders name a repeat respondent. A repeat appearance can reflect one sales campaign reaching several registration states; it does not by itself show repeated misconduct after an order. The registry CSV lists every respondent as the regulator names it, so readers can check.

Item 3 of the FDD must disclose pending administrative actions and any currently effective injunctive or restrictive order from an action brought by a public agency (16 CFR 436.5(c)); a cease-and-desist consent order is one kind. Our litigation disclosure study measures how often Item 3 lists regulatory actions.

How to check a franchisor for state enforcement actions

Check three places: the FDD, the state order lists, and this registry. Item 3 of the FDD must disclose pending administrative actions and currently effective orders by public agencies under franchise and similar laws (16 CFR 436.5(c)). Then search the state lists directly: Washington DFI, California DFPI, Maryland Securities Division, Minnesota CARDS and Virginia SCC. The registry CSV on this page links each order to its document.

No single list is complete. GAO found that one of the five states it reviewed had eight actions that were not public (GAO-23-105338), and New York, which publishes no franchise order list, announced a settlement of more than $3.9 million with a fitness franchisor on June 9, 2026 (New York Attorney General). A franchise consultant or broker should run the same checks; see what a franchise consultant does and our broker registration tracker for the 49 orders against brokers and sellers.

Our guide to buying a franchise covers the rest of the due diligence.

Which states publish order lists

Eight of the 14 registration states listed by NASAA and the FTC have a public order list we could read. (GAO-23-105338 gives the list.) We read every list on October 14, 2026 and downloaded every listed document dated from 2015 (Wisconsin: franchise-tagged files only). Virginia’s list starts in 2022 and South Dakota’s in 2017, so their earlier years are blank, not zero. Illinois, Michigan and New York publish no franchise order list, Indiana’s search requires a reCAPTCHA token, North Dakota lists news items only, and Hawaii’s list ends in 2014.

How the registry was built and checked

Every row comes from a regulator’s own list and order document. Scripts collected the lists, downloaded the orders, extracted text (with OCR for scans) and coded each order from the sections it charges and the conduct it describes. We re-read randomly drawn orders against the source: on the first pass, 9 of 218 coded cells in 20 orders differed (4.1%); two further samples of 10 had 9 of 120 (7.5%) and 3 of 120 (2.5%) wrong after successive rule fixes.

Independent blind check. A second reader, who had not seen our coding, then coded 20 other randomly drawn orders: 8 of 200 fields differed from the registry (4.0%; 3.5% if one judgment call is scored our way). The main cause was background passages: Washington orders often describe a respondent’s earlier orders in other states, and penalty and rescission amounts from those passages had been read as this order’s terms. We changed the rules for every row (penalties and rescission now count only from the order’s own operative terms; recitals of other regulators, court cases and earlier orders are skipped for all codes; the misspelling ‘recission’ is matched; penalties that apply only on a later breach are ignored), then re-read every changed row. 58 of 562 orders changed in at least one field. All 60 hand-read orders, including the blind sample, now match the registry; that agreement is not an independent estimate, so treat category shares and penalty totals as accurate to within a few points.

Update log

Checked October 14, 2026; next check mid-November 2026. Each update re-runs the collectors on the eight lists, codes new documents with the same rules, and hand-checks a fresh random sample. The latest orders read were dated 2026-10-02 (California), 2026-09-30 (Washington), 2026-08-28 (Maryland), 2026-07-30 (Minnesota) and 2026-03-13 (Virginia).