Franchise marketing
rules.

Franchise marketing sits under three sets of rules at once. The Franchising Code covers the money franchisees pay into the marketing fund. The Australian Consumer Law covers what every ad, page and post says to customers. Google's own policies cover how each location shows on Search and Maps, and what you can do to collect reviews.

The Code is national, and the ACCC enforces it along with the Consumer Law. In NSW, Fair Trading publishes its own guide to advertising laws for businesses, and the other states' fair trading offices do the same.

This page is a marketer's summary of the parts that touch customer marketing. It isn't legal advice, and it leaves out franchisee recruitment, which is a different set of rules for a different audience.

The new Franchising Code started on 1 April 2025. Under it, the marketing fund is one kind of specific purpose fund, alongside funds for technology, training and refurbishment. The fund rules have applied to every fund type since 1 November 2025.

The practical changes are clear. Contributions sit in a separate bank account. Franchisor-run corporate stores pay in on the same basis as franchisees. The franchisor prepares an annual statement for each fund within 4 months of year end, then gives it to contributing franchisees within 30 days.

The statement must be independently audited, unless 75% of contributing franchisees in Australia vote that year that no audit is needed. The ACCC says that vote should happen within 3 months of year end. The audit report goes to franchisees within 30 days of the franchisor receiving it.

The ACCC's guidance on marketing funds lists four kinds of cost the money can go on. Everything else needs to fit one of them.

• Costs disclosed in the disclosure document.
• Legitimate expenses related to the fund's purpose.
• Expenses most contributing franchisees have agreed to.
• Reasonable costs of administering and auditing the fund.

The ACCC also gives examples of running costs. External audit fees, a fair share of the wages of staff who run the fund, and bank fees are likely reasonable. Inflated overheads, executive salaries and whole-of-business software licences likely aren't.

One line in that guidance matters to every franchisee: paying into a marketing fund doesn't guarantee your own business will be promoted with it. If the franchisor must spend part of the fund for each franchisee's benefit, the disclosure document has to say so.

A fund statement isn't a formality. It has to show receipts and expenses in enough detail to show how, when and on what money was spent, plus the percentage spent on running and auditing the fund. The ACCC says it should make sense to an ordinary reader, not just an accounting professional.

Courts have taken this seriously for years. In 2019 the Full Federal Court said Ultra Tune's statements, which reported spend on television advertising, gave no meaningful information without details such as where the ads ran. In 2023 Delicia Franchising paid an $11,100 penalty for not giving franchisees its fund statement, an example the ACCC cites in its guidance.

Spending on things franchisees didn't sign up for is the bigger risk. In 2022 the ACCC settled a case against Retail Food Group, alleging some Michel's Patisserie fund payments covered expenses which were not legitimate marketing expenses. RFG didn't admit the allegations, and agreed to pay $5 million to franchisees who paid marketing levies.

For a marketer, there's an upside. A detailed statement is halfway to a performance report. If you can say which channels ran, where and when, you can also say what they did for the network. The fund check on the franchise hub tests your lines for detail.

The Consumer Law's advertising rules apply to every business. What's different in a franchise is that one ad speaks for dozens of separately owned stores. The ACCC says fine print can't conflict with the overall message, and a 'storewide' or 'all products' promotion with exclusions in the small print may still mislead.

Three patterns cause most of the trouble. A price that varies by store, advertised as if it doesn't. An offer some stores skip, flagged only as 'participating stores' in a footnote. And a deal that sells out at busy stores on the first weekend. NSW Fair Trading lists the last one as bait advertising, along with showing part of a price without the total including GST.

The ACCC also says a business is responsible for all its communications, including its website, social media and what staff say. In a network, head office and franchisees both need to know who signs off what, before it runs.

Paste the copy for a national or regional promotion, then tick how the network will actually run it. It flags the wording most likely to cause trouble at store level, before the ads go out.

Google's Business Profile guidelines are strict for chains. All locations in the same country must have the same name, and location details like a suburb or a landmark don't belong in it. Locations that provide the same service share the same category. And there's one profile per location, never two.

Reviews have their own policy. Google bans offering incentives for reviews, selectively asking for positive ones, and asking staff to collect a certain number. That rules out a common network idea: a monthly prize for the store with the most new five-star reviews.

Australian law adds its own layer. The ACCC says any incentive must be applied whether the review is positive or negative, and clearly disclosed. Google's policy is stricter, so on Google, follow Google's.