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FIELD FISHER WATERHOUSE ALLIANCE
Disclosure Obligations in Germany

December 2005




Field Fisher Waterhouse

35 Vine Street
London
EC3N 2AA
www.ffw.com



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Comments



Germany is often missed out when franchise experts compile a list of disclosure countries. However, those who are familiar with German franchise law are well aware that Germany is in practice a disclosure country. German laws knows a general obligation to disclose important information to the other contractual party. This applies in particular where one party (usually the franchisor) has superior knowledge. Two basic disclosure obligations are thought to arise under German law:

  • All information which the franchisor makes available to the franchisee must be correct (no misrepresentation)
  • There is an obligation on the franchisor to disclose certain key data to the franchisee, even if the franchisee does not ask for this information.

It is of course the second item which causes concern. What exactly is "key information"? The German Franchise Association makes certain recommendations as to the information which should be disclosed and some franchisors follow these recommendations. In addition, German case law continues to produce surprising additional requirements. Here are some of the items which franchisors should consider including in their disclosure document for Germany:

  • Number of stores operating in Germany, together with success and failure rates
  • The fact that the franchisee is the first German franchisee (if that is the case)
  • Whether or not there has been a pilot operation in Germany
  • Certain financial information about investment cost, amortisation rate and likely break-even point
  • In a recent decision of May 2005, the Essen Regional Court suggested that, in addition, the franchisor should be obliged to provide the franchisee with a detailed feasibility study for the proposed franchise location.

The current view taken by most franchisors is that the franchisee knows his local town better than the franchisor and should take responsibility for selecting the best location. Most franchisors provide abstract criteria for location selection but quite rightly refuse to analyse a specific site. In our view, failure to conduct a feasibility study does not amount to failure to disclose unless the franchisor knowingly withholds existing data. We understand that the case is under appeal.

If you would like any further information please contact
Babette Märzheuser-Wood or Mark Abell


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