Of all 23 items in a Franchise Disclosure Document, Item 19 generates the most questions -- and the most confusion. It's the section where franchisors can disclose historical financial performance data for their franchise system. Notice the word "can." It's not required.
That optionality alone tells you something important.
What Item 19 Actually Is
Item 19 is formally titled "Financial Performance Representations." When a franchisor includes it, the section typically contains some combination of:
- Average or median gross revenue across franchise locations
- Revenue breakdowns by geography, unit type, or tenure
- Cost of goods sold or gross profit margins
- Net income or owner earnings (less common but most useful)
The FTC requires that any financial performance claim be substantiated and that the franchisor disclose the basis for the claim -- how many units are included, what time period is covered, and what percentage of units achieved the stated results.
Why Some Franchisors Skip It
Roughly 40% of franchise systems choose not to include any Item 19 data. The reasons vary, but the most common are:
- The numbers aren't impressive -- If system-wide performance is mediocre, disclosing it creates a marketing problem
- High variability -- When outcomes range wildly by market, a single average can be misleading (and legally risky)
- Legal caution -- Item 19 claims that prove inaccurate can trigger lawsuits; some franchisors avoid the liability entirely
- New systems -- Franchisors with few locations may not have enough data for a meaningful disclosure
The absence of Item 19 isn't automatically a red flag, but it should make you ask: "If the numbers were strong, why wouldn't they share them?"
How to Read Item 19 When It's Included
If the franchisor does disclose financial performance data, here's how to extract maximum value:
Look for Medians, Not Just Averages
Averages can be skewed by a handful of top-performing locations. If the average revenue is $800,000 but only 30% of units achieve that, the number is misleading. The median (50th percentile) tells you what a typical location actually does.
When FranchiseLens analyzes Item 19, we flag whether the disclosure uses mean or median figures and, where possible, calculate both.
Check the Sample Size
"Average revenue of $1.2 million" sounds impressive. But if it's based on 12 company-owned locations in prime markets, it tells you nothing about what your franchise will do. Look for:
- How many total units exist vs. how many are included in the data
- Whether company-owned units are mixed in with franchisee-owned units
- Whether the data excludes units open less than 12 or 24 months
Understand the Segmentation
Good Item 19 disclosures break data into segments. Common segments include:
- By geography -- Performance varies significantly by region and market size
- By unit age -- A location in its fifth year typically outperforms one in its first year
- By format -- Some franchise systems have multiple unit types (express, full-size, kiosk)
If the disclosure provides only a single system-wide number with no segmentation, you're working with an incomplete picture.
Calculate the "Achievability Rate"
The FTC requires franchisors to disclose the percentage of units that met or exceeded the stated figure. This is the single most important number in Item 19.
If the average revenue is $500,000 but only 25% of units hit that number, the "average" is aspirational, not typical. Look for disclosures where at least 50% of units meet or exceed the stated figure.
What Item 19 Doesn't Tell You
Even a detailed Item 19 has significant gaps:
- It rarely shows net profit -- Revenue data without expense data tells you the top line, not what you'll take home
- It doesn't account for your market -- National averages may not reflect the economics of your specific location
- It's backward-looking -- Past performance doesn't guarantee future results, especially in rapidly changing industries
- It excludes failed units -- Locations that closed during the reporting period may be excluded from the data
How to Supplement Item 19
Given its limitations, Item 19 should be your starting point, not your conclusion. Supplement it with:
- Franchisee conversations -- Call current franchisees listed in Item 20 and ask about actual revenue and profitability
- Industry benchmarks -- Compare the disclosed figures against industry averages for the same category
- Your own financial model -- Use Item 19 data as a revenue assumption, then layer in your actual costs (rent, labor, etc.) for your specific market
- Third-party data -- Check whether the brand's performance claims align with industry reports or publicly available data
The Bottom Line
Item 19 is the closest thing to a financial crystal ball that the FDD provides. When it's there, read it carefully. When it's not, ask why. Either way, never base a six-figure investment on a single number.
FranchiseLens extracts and benchmarks Item 19 data across every franchise in our database, making it easy to see how one system's financial disclosures compare to its peers. Start your research with the data, and build your confidence from there.