Saskatchewan Joins the Regulated Fold: What Franchisors Need to Know

It has been nearly a decade since a province has enacted franchise legislation in Canada, but Saskatchewan is set to change that. Its new The Franchise Disclosure Act (the “Act”)[1], coming into force on June 30, 2026, and its accompanying regulations brings the province into the regulated fold, introducing statutory disclosure requirements for franchisors operating in Saskatchewan. While the regime largely mirrors the models found in other provinces, it introduces several distinctive elements that franchisors need to understand, changes that close a longstanding regulatory gap and create new national compliance considerations that franchisors should begin planning for now.

Legislative Background

Saskatchewan passed the Act in 2025, followed by draft regulations released in April of that year. The draft signaled the province’s intent to align its franchise regulation with the six other provinces that already regulate franchising (the “Regulated Provinces”)[2], while leaving certain provisions open for further refinement. Recent amendments have since clarified many of these points and confirmed the implementation timeline.

Key Features of the New Legislative Regime

The Act and The Franchise Disclosure Amendment Regulations (the “Regulations”)[3] set out the framework for Saskatchewan’s disclosure obligations. Several features are particularly noteworthy for franchisors:

1. New and Clarified Definitions: The Regulations introduce definitions for several previously undefined but critical terms, including “officer”, “earning projection”, and “foreign jurisdiction”. These additions provide clearer guidance on which individuals are captured by disclosure obligations and when financial performance information becomes regulated. This greater precision should give franchisors more certainty when preparing their franchise disclosure documents and designing internal compliance frameworks.
2. A Narrower Definition of “Franchise”: The Act adopts a more limited definition of “franchise” than Ontario’s Arthur Wishart Act,[4] aligning instead with provinces such as British Columbia and Manitoba. Under the Act, a franchise relationship exists only where a payment is required and “the franchise or the franchisor’s associate exercises significant control over, or provides significant assistance in” the franchised business. By contrast, Ontario’s regime applies where the franchisor merely holds the right to exercise such control or provide assistance, regardless of whether that right is exercised. This difference may affect whether certain business models are captured under the Act.
3. Financial Statement Flexibility: The Regulations confirm that franchisors may provide financial statements prepared in accordance with U.S. GAAP audit or review standards. This aligns the Act with recent amendments to the Arthur Wishart Act in Ontario and may offer added flexibility for U.S.-based or cross-border franchisors, a development that other Regulated Provinces may eventually choose to follow as well.
4. Substantial Compliance Standard: The Act adopts a substantial compliance approach, meaning minor technical errors or omissions in a disclosure document should not, on their own, invalidate a disclosure document that otherwise meets the Act’s purpose. This standard strikes a balance between protecting franchisees and ensuring that franchisors are not unduly penalized for technical or immaterial deficiencies.

How Franchisors Can Prepare for Implementation

With the regulatory framework now largely finalized, franchisors can begin preparing for implementation and the corresponding increase in compliance obligations, particularly those operating across multiple Canadian jurisdictions. Although the Act aligns closely with other Regulated Provinces, certain distinctions may require tailored adjustments to existing disclosure documents and compliance processes. The June 30, 2026 implementation date provides a clear and practical transition window that aligns with most franchisors’ fiscal year-end planning and annual disclosure update cycles. This extended lead time supports a smoother transition and helps minimize operational and business disruption once the Act comes into force.

To best prepare, franchisors should use this time to:

• Integrate Saskatchewan-specific requirements into their annual disclosure documents.
• Conduct internal legal and compliance reviews to confirm alignment with the Act.
• Train relevant personnel and update internal systems and processes to support the incoming regime.

Looking Ahead

As the implementation date approaches, franchisors should focus on meeting Saskatchewan’s specific statutory obligations under the Act. By proactively preparing now, franchisors can minimize disruption, avoid compliance pitfalls, and be ready for a seamless transition when Saskatchewan’s new regime takes effect.

About the Author

Sydney is an associate in the Franchise Law Group and Business Advisory Group at Cassels. Her practice focuses on providing practical, business-oriented guidance to franchisors on all aspects of franchise law, supporting clients operating in a wide range of industry sectors.

Any article or other information or content expressed or made available in this Section is that of the respective author(s) and not of the OBA.