Franchising · FDD audits
FDD Audits for Franchisors (Item 21)
Audited statements for your Franchise Disclosure Document, done in time for the 120-day update.

FDD audits

Audited financial statements for your Franchise Disclosure Document (Item 21)

Greywood CPA audits franchisors' financial statements for Item 21 of the Franchise Disclosure Document (FDD). Under the FTC Franchise Rule, a franchisor's FDD must include financial statements prepared under U.S. GAAP and audited by an independent CPA under U.S. generally accepted auditing standards. We are a licensed CPA firm (Virginia Board of Accountancy firm license #134961) working nationwide, at a fixed fee.

Established franchisors generally include audited balance sheets for the last two fiscal year-ends and audited statements of operations, equity and cash flows for each of the last three fiscal years. The FDD must be updated within 120 days after fiscal year-end, so the audit has to be finished in time for your attorney to file and register the renewal.

Last reviewed: November 2026

What does Item 21 require?

StatementPeriods
Balance sheetAudited, as of the end of each of the last two fiscal years
Statements of operations, equity and cash flowsAudited, for each of the last three fiscal years
Unaudited interim statementsSometimes needed, for example when a state asks or the FDD is issued well after year-end

Start-up franchisors can generally phase in audited statements. See start-up franchisor financial statements.

Parent, affiliate and guarantor financial statements

If a parent company guarantees the franchisor's obligations or commits to perform post-sale obligations, the parent's financial statements are generally required too. A franchisor can sometimes use an affiliate's audited statements instead of its own when that affiliate absolutely and unconditionally guarantees the franchisor's duties, with the guarantee included in the FDD. We help you choose the structure with your franchise attorney before the audit is planned.

What a franchisor audit focuses on

  • Initial franchise fees and how they are recognized under ASC 606
  • Royalties, recognized as franchisee sales occur
  • Brand or advertising fund contributions and spending, often presented gross
  • Deferred revenue for unopened units and area development agreements
  • Related-party transactions with affiliates, suppliers and owners
  • Going concern, which state examiners read closely for younger franchisors

See franchisor revenue recognition.

Working back from the 120-day deadline

Weeks after year-endWhat happens
1–3Books closed, deferred revenue and fund schedules updated
3–8Audit fieldwork
8–11Draft statements reviewed, opinion issued
By day 120Attorney finalizes and files the FDD renewal in registration states

Registration states may take weeks to approve a renewal, so the earlier the audit finishes, the less risk of a sales gap.

How the engagement works

  1. Scoping callDay 1

    A 30-minute call about your organization, who needs the report and your deadline.

  2. Fixed-fee proposalWithin 1–3 business days

    Scope, report type, timeline and one fixed fee, in writing.

  3. One request listWeek 1

    Everything we need, uploaded through a secure portal.

  4. Fieldwork and draftSet in your proposal

    Remote testing, then a draft for your review.

  5. Signed reportOn or before the agreed date

    A CPA partner signs, and we walk you or your board through the results.

Why franchisors choose Greywood CPA

  • Fixed fee, agreed first. No hourly billing and no surprise invoices.
  • Senior people on your file. Every engagement is led by a senior professional and signed off by a CPA partner. Meet the team.
  • Licensed and registered. Virginia Board of Accountancy firm license #134961, AICPA member, with out-of-state registrations where required. See our credentials.

Related

FDD audit FAQs

Does a franchisor need audited financial statements?

Yes, for the Franchise Disclosure Document. Item 21 of the FTC Franchise Rule requires financial statements prepared under U.S. GAAP and audited by an independent CPA, with a phase-in available to start-up franchisors.

Which years must be audited in Item 21?

Generally audited balance sheets for the last two fiscal year-ends and audited statements of operations, equity and cash flows for each of the last three fiscal years.

When does the FDD have to be updated?

Within 120 days after the close of the franchisor's fiscal year, which includes the new audited financial statements.

Can we use our parent company's financial statements?

Sometimes. If an affiliate or parent absolutely and unconditionally guarantees the franchisor's obligations, its audited statements may be used, with the guarantee included in the FDD. If a parent guarantees obligations, its statements are generally required.

How do your fees work?

We quote one fixed fee in writing before any work starts, based on the number of entities, units and the complexity of your fee and fund arrangements.

FDD renewal deadline coming up?

Tell us your fiscal year-end. A senior CPA will send a fixed-fee proposal within 1–3 business days.