What Item 19 Says, and What It Does Not

Item 19 is a financial performance representation: a statement by the franchisor about the actual or potential sales, income or profit of its units. Under the FTC Franchise Rule (16 CFR 436.5(s)) a franchisor is not required to make one, but if it makes any such claim anywhere, it has to be in Item 19 with a reasonable basis and the material assumptions behind it. Everything a brand page prints under "What a unit sells" comes from that item, and nothing is estimated where it is missing.

Three shapes an Item 19 takes

Of the 165 brands on the site as of the latest tranche, 98 print an Item 19 with one unit revenue figure, 47 have an Item 19 with no single figure, and 20 make no representation at all. The brand page says which, and the index marks the second and third kinds "present, no single figure" and "no Item 19".

• One figure. Jersey Mike's 2026 FDD gives a median unit volume of $1,305,850 and an average of $1,367,578 across 2,606 traditional franchised restaurants for the period 2025-01-01 to 2025-12-28 (Item 19, pages 50 and 51). That is the shape the revenue-to-investment ratio needs.
• Present, no single figure. Snap-on's 2026 FDD splits 2,802 reporting franchises into thirds and gives an average and median for each third (Item 19, page 57) with no combined figure. Brightway Insurance splits 272 locations by number of producers (pages 49 and 50). Hampton by Hilton reports 2025 occupancy of 71.0%, an average daily rate of $149.08 and revenue per available room of $105.90 (pages 76 to 83), not revenue per hotel. Wendy's Table 1 is an image in the filed PDF and its figures did not extract. In each case the franchisor's own structure is shown and the ratio is undefined.
• Absent. Subway's 2026 FDD makes no financial performance representation (Item 19, page 84). So do Roto-Rooter (page 28), H&R Block (page 35) and Keller Williams (page 73). The page says so and shows nothing.

Median and average are different numbers

Most Item 19 statements print both. The average is the total across the sample divided by the count; the median is the unit in the middle. When a few units sell far more than the rest, the average sits above the median. Stanley Steemer's 2026 FDD reports a median of $1,179,370 and an average of $1,742,025 across 208 franchisees for calendar 2025 (Item 19, pages 74 to 76), a gap of $562,655. Oxi Fresh reports a median of $110,981 and an average of $156,833 across 178 active operators (pages 46 to 50). McDonald's is closer: a median of $3,887,000 against an average of $4,057,000 across about 12,212 domestic traditional franchised restaurants for calendar 2025 (pages 34 to 36).

The site uses the median for its ratio because it is the figure a typical unit is nearer to. Where a franchisor prints only an average, the ratio is left undefined rather than computed on the wrong measure: The UPS Store's 2026 FDD gives average adjusted gross sales of $724,293 across 5,058 traditional centers for calendar 2025 (Item 19, pages 72 to 75) and no median.

The sample is the franchisor's choice

Every Item 19 defines who is in it, and the definition is where the number is made. Dunkin's 2026 FDD median of $1,297,694 covers 7,010 franchised restaurants that were open the full fiscal year, not combo units, not multi-brand, not self-serve and not part-time (Item 19, pages 87 to 90). Crumbl's median of $1,093,071 covers 776 franchised locations that operated continuously through calendar 2025 and submitted complete financial reports, which the filing says is about 74% of eligible outlets (page 70). Anytime Fitness's median of $398,982 covers 1,683 centers open the entire twelve months to 2026-02-28 that used the franchisor's coaching program and reported coaching revenue (pages 54 and 55).

Units that opened during the year, closed during the year, or did not report are usually outside the sample. A median over units that survived a full year is not the median of every unit that existed. That is why the page prints the sample description and the period beside every figure instead of the figure alone.

The measure is not always sales

"Revenue" means what the franchisor defines it to mean. Jersey Mike's unit volume is gross sales less tax, refunds, discounts, coupons and donations. Ellie Mental Health reports collected revenue per clinic, $765,302 median across 189 franchised clinics for 2025 (Item 19, pages 59 to 62). Brightway reports gross commissions. Keller Williams has no Item 19, and its unit is a brokerage office whose income is commission. A ratio built on one brand's measure cannot be compared to another's, which is why the site shows bands within a category and never a cross-category ranking.

What this guide does not cover

Item 19 is revenue, not profit. A few franchisors also print cost or earnings tables (Penn Station's unit financial data includes controllable costs, overhead and EBITDA for 317 restaurants, pages 61 to 64), and the page records that they exist, but the site does not compute a profit figure from them. It also never fills an absent Item 19 from any other source: a content-farm estimate of what a Subway sells is not a representation the franchisor made.

The brand index lists the median for every brand with a single figure, and each brand page carries the measure, sample and period beside it.

Sources

• 16 CFR 436.5(s), Item 19: Financial performance representations
• The 2026 FDDs of the brands named, as filed with Wisconsin DFI, Item 19 pages as cited; each brand page links its filing record at Wisconsin DFI Franchise Search.

This guide is informational only. It is not financial, legal or investment advice, and Unitnomics is not affiliated with any franchisor, state regulator or the FTC. It reports what a franchisor filed and what the site computed from it; it does not advise on whether to buy a franchise.

Last reviewed: November 2026 · Against 16 CFR 436.5(s) and the 2026 FDDs cited below.