On October 8, Maryland Securities Commissioner Melanie Senter Lubin announced a Fast-Track Program, launching January 1, to expedite franchise renewal registrations. The program will benefit franchisors, franchisees, and the Maryland Securities Division by encouraging earlier filings and enabling faster approvals.
Goal
The intended goal of the program is to accelerate the registration review and approval process for Maryland franchisors who substantially complete their annual Franchise Disclosure Document (FDD) updates by February each year, in order to secure a registration renewal by late April – generally less than 30 days after new financial statements are issued.
Background
The Fast-Track Program will be implemented starting January 1, 2026, and will allow eligible franchisors to file their renewal application by February 1, cure any deficiency comments, and obtain pre-clearance, in advance of the April 10 deadline for incorporating Item 21 financial statements and disclosures into the FDD.
The Maryland Securities Division implemented the program with the goal of encouraging franchisors to submit renewal applications earlier in the year, reducing the volume of applications the division receives between March and May and enabling franchisors’ renewal applications to be registered more quickly. The division highlighted that in 2025, it received 79% of its 1,719 franchise applications between March and May, with 45% being filed in April alone. The new program targets franchisors who can file their renewal FDD early and can benefit from the expedited review process.
Eligibility
To be eligible for the Fast-Track Program, the franchisor must:
- Have a fiscal year ending between December 24 and January 7;
- Have an FDD currently registered in the State of Maryland at the time of filing the franchise renewal application, prior to the February 1 deadline;
- Not be subject to a pending investigation or enforcement matter with the Maryland Securities Division at the time of the fast-track renewal application or during the duration of the fast-track review; and
- Understand that the Securities Division reserves the right to reject/remove any FDD filing from the program at any time.
What This May Mean for You
Eligible franchisors may benefit from faster registration timelines, reduced compliance pressure during peak filing season, and improved certainty around renewal approvals. Please note: this program may not be right or optimal for all franchisors.
The Maryland Securities Division is planning to host two webinars, one in late October and another in early November, to go over the program’s logistics and address any questions. Please see the Fast-Track Program Guidelines and FAQs provided by the state for more information.
Franchise legal counsel can help franchisors navigate the program by preparing and submitting required documents on time, responding to deficiency comments, and ensuring compliance with Maryland’s filing guidelines to maintain eligibility.
We will continue to monitor updates from the Maryland Securities Commissioner regarding the Fast-Track Program. If you have any questions regarding this program, please reach out to Mark Kirsch or Liz Dillon, or your regular Lathrop GPM attorney.
*Asad Imam, a Franchise Law Clerk for Lathrop GPM, also contributed to this legal alert.