If you buy a franchise in France, Italy, Spain or Belgium, the law requires the franchisor to give you key information about the business, in writing, a set time before you sign. If you buy one in the UK, it does not. That difference sits at the heart of the debate about whether British franchisees need stronger protection.
With the UK government now reviewing how franchising is regulated, including how it is done in other countries, it is worth looking at what the European models actually do, and what a UK version might look like.
Where the UK stands
The UK has no franchise-specific law and no general legal duty on a franchisor to disclose information before a franchise agreement is signed. The relationship is governed by the agreement itself and by general contract, competition and intellectual property law.
There is voluntary self-regulation. The British Franchise Association's code of ethics, which is based on the European Code of Ethics for Franchising, expects members to disclose information. But it only applies to franchisors who choose to join, and it is enforced by the association rather than by law. Many franchisors operating in the UK are not members.
In practice, this means a prospective franchisee's protection depends largely on asking the right questions, taking advice and reading the agreement carefully, often at a time when they are excited about a new venture and may be under pressure to sign.
France: the Loi Doubin
France introduced its disclosure law, known as the Loi Doubin, in 1989. It applies to anyone who makes a name, brand or sign available to another person in return for an exclusive or quasi-exclusive commitment, which covers most franchises.
The franchisor must provide a disclosure document at least 20 days before the agreement is signed, or before any payment is made. It must include information about the franchisor and its management, the history and state of the network, the number of businesses in it and how many have left, the duration and renewal terms of the agreement, and the general and local state of the market. French courts have been prepared to cancel agreements where key information was missing or misleading and the franchisee's consent was affected as a result.
Italy: Law 129 of 2004
Italy has a dedicated franchising law, Law 129 of 2004. The franchisor must give the prospective franchisee a full copy of the agreement at least 30 days before signing, together with prescribed information about the business, the network and any legal proceedings.
The law also requires the franchisor to have tested its business model before franchising it, and sets a minimum length for agreements, so that a franchisee has a reasonable chance to recover their investment. Where a franchisor gives false information, the franchisee can seek to have the agreement cancelled and claim damages.
Spain and Belgium
Spain requires the franchisor to provide written information about itself, the business and the network at least 20 days before the agreement is signed or any payment is made.
Belgium's law on pre-contractual information, now part of its Code of Economic Law, requires a draft agreement and a separate information document to be provided at least one month before signing. The document must cover the key obligations, fees, renewal and termination terms, and the economic prospects of the business. If the rules are not followed, the franchisee can ask a court to cancel the agreement within two years.
Good faith throughout
Beyond disclosure, several European legal systems include a general duty to negotiate and perform contracts in good faith. In countries such as France, Belgium, Spain, the Netherlands and Germany, failing to act in good faith during negotiations can lead to liability even before a contract is signed.
English law takes a different starting point. There is no general duty of good faith in commercial contracts, although courts have sometimes implied such a duty in long-term "relational" contracts, and a franchise agreement can be one of them. Whether it applies depends on the facts, which leaves franchisees with uncertainty rather than a clear rule.
Does regulation work?
Disclosure laws are not a cure-all. Franchisors in regulated countries still fail, and disputes still happen. Critics also point out that long disclosure documents can be hard for a first-time franchisee to understand without advice, and that rules can add cost for small franchisors.
But the European approach does change the balance in important ways. Franchisees receive the core facts in a standard form before they commit their savings. Franchisors know that withholding or misstating key information can unravel the agreement. And when disputes do arise, both sides start from a clearer, documented position about what was said before signing. That alone removes one of the most common sources of franchise disputes in the UK: arguments about what the franchisee was told.
What the UK could learn
None of these laws prevents a franchise from failing, and none removes the need for franchisees to do their homework. What they do is make sure the franchisee has the key facts in time to think, take advice and walk away. A UK approach could draw on the best of each:
- A mandatory disclosure document, given a set period before signing, covering finances, fees, the network's history, litigation and the experience of current and former franchisees
- A cooling-off period, so that franchisees are not pressured into signing on the spot
- A requirement that the business model has been proven before it is franchised
- A clear statutory duty to act fairly and in good faith during the agreement, not only before it
- Limits on one-sided changes to payments and charges during the term
- Real remedies, including cancellation and damages, where the rules are broken
- An affordable, independent route to resolve disputes
Where the debate goes next
The government has asked the Centre for Economic Policy Research to examine franchising models used internationally, alongside a study of the UK market by the Department for Business and Trade and the British Franchise Association. Those studies will inform whether, and how, the UK legislates.
We have lobbied the Government hard for franchise legislation of the kind many European countries already have. As of June 2026, MPs have told us this is now being investigated and worked on. We believe a clear disclosure law and a statutory duty of fair dealing would prevent many disputes before they start.
Until the law changes
For now, UK franchisees must protect themselves. If you are thinking of signing, ask for the information a European franchisee would receive by law, and treat any refusal as a warning sign. If you have already signed and things have gone wrong, get an honest, independent view of your position. Initial discussions with us are free and in confidence.