On May 12, 2026, Maryland enacted H.B. 730, amending the Maryland Franchise Registration and Disclosure Law, MD. Bus. Reg. Code Ann. §14-201 et seq. Effective October 1, 2026, the new law extends the statute of limitations for both state enforcement actions and private civil claims, establishes new franchisee association rights, and codifies the Franchise Disclosure Document Renewal Fast-Track Review Pilot Program.

Franchisors registered or considering registration in Maryland should ensure their franchise disclosure documents and agreements are updated before offering or selling franchises to Maryland prospects after the effective date.

1. Extended Statute of Limitations for State Enforcement Actions

Under the amended law, the statutory period during which the Maryland Securities Commissioner may exercise enforcement authority under the Maryland Franchise Law, including bringing enforcement actions for violations, increases from three years to five years after the violation occurs. Franchisors face a longer window of exposure, making accurate, complete, and timely filings with the Securities Division and compliance with franchise sales practices essential.

2. Revised Statute of Limitations for Private Civil Actions

The amendments also revise the statute of limitations for private franchisee claims. Previously, a franchisee had three years after the grant of the franchise to bring a civil action. Under the new framework, a franchisee may bring a private civil action within the earlier of (i) four years after the grant of the franchise, or (ii) two years after the date on which the franchise opened to the public. This provision applies only to a franchisee who is a resident of Maryland or to a franchised business that operates, or will operate, in the state.

While the outer limit extends from three to four years, the two-year post-opening trigger may shorten the effective window for franchisees who open quickly. Franchise documents and the Maryland addendum must now provide that claims arising under the Maryland Franchise Law must be brought by the earlier of four years after the franchise is granted or two years after the date the franchise opened to the public.

3. Franchisee Right to Join Trade Associations

The amended law establishes that all franchisees have the right to join and participate in trade associations consisting of other franchisees of the same franchise for any lawful purpose. The statute prohibits franchisors from directly or indirectly restricting or inhibiting this right, whether through officers, agents, or employees, and creates a private cause of action for violations. Franchisors should review their franchise agreements, operations manuals, and other governing documents to confirm they do not contain provisions that could be construed as limiting franchisee association rights, and should train internal teams accordingly.

4. Fast-Track Review Pilot Program Codified

The FDD Renewal Fast-Track Review Pilot Program, implemented by the Securities Division during the 2026 franchise renewal season to expedite franchise renewal registration, is now formally established by statute under §14-219.1. Codification provides franchisors greater certainty that the expedited review process will remain available in future renewal cycles.

5. Filing and Disclosure Implications

The Maryland Securities Division has taken the position that registered franchisors are not required to file an amendment or cease offering and selling franchises solely to reflect the October 1 changes. However, as of October 1, 2026, franchisors must update their FDDs and related agreements, or addenda thereto, to comply with the new amendments before providing those documents to prospective Maryland franchisees. The Securities Division will review these revisions when the franchisor files its next amendment or renewal.

If any franchise document conflicts with the statutory amendments, the document must be revised, and franchisors should not rely on the no-action position as a basis to continue using non-compliant materials.

Looking Ahead

Maryland's amendments reflect the continued expansion of franchisee protections and regulatory enforcement authority across state franchise laws. The new two-tiered statute of limitations for private civil actions reinforces the need for compliance practices that extend from franchise award through opening. The franchisee association protections align with a broader national trend of states enacting relationship laws that limit franchisor control over franchisee conduct beyond the franchise agreement.

Franchisors operating in multiple registration states should monitor similar legislative developments and evaluate whether their standard-form agreements require broader revisions. Franchisors should update their Maryland franchise disclosure documents, franchise agreements, and Maryland addenda to reflect the amended statute of limitations language and association rights provisions before October 1, 2026, and coordinate these updates with their next amendment or renewal filing.

Contact the Larkin Hoffman franchise team to discuss how these amendments affect your franchise system, and to ensure your Maryland filings are compliant ahead of the October 1 effective date.