Reading a Coffee Franchise Item 19 Without Getting Played

Item 19 is the one part of a Franchise Disclosure Document where a franchisor is legally allowed to talk numbers with you. Every other item describes fees, obligations, and legal terms. Item 19 is where, if the company chooses to, it shows you how existing locations have actually performed. That “if it chooses to” is doing a lot of work, and most people skip past it on their first read.

This is not a ranking of coffee brands and it is not going to tell you what you’d earn owning one. Nobody can tell you that, and anyone who does is breaking federal law. What this piece does is teach you to read the disclosure that’s actually there: what format it’s in, what it can support, and what it quietly leaves out. You bring your own math after that.

We did not test any of these franchises or visit any locations. This is desk research pulled from FDD filings, franchisor disclosures, and the secondary services that track them, with the filing year noted for every figure. Where sources disagreed or a figure looked thin, we say so.

What Item 19 actually is

Item 19 is short for a Financial Performance Representation, or FPR, and the rule governing it lives in the FTC’s Franchise Rule at 16 CFR Part 436. The rule doesn’t force a franchisor to disclose anything about how its locations perform financially. What it does say is that if a franchisor makes any financial performance claim to a prospect, whether in writing, in a sales pitch, or in a slide deck at Discovery Day, that claim has to be written down in Item 19 and backed by a reasonable basis at the time it’s made.

“Reasonable basis” is a legal standard, not a specific number of data points. Franchise attorneys generally read it as information solid enough that a prudent business person would rely on it before investing real money. The franchisor also has to keep written substantiation on file, the paperwork a court or regulator would ask for if a claim gets challenged later.

Franchisors have two options for how to build an FPR, and the rule treats them differently:

Historic representations. These describe what existing outlets, or some named subset of them, actually did in a defined past period. If a franchisor goes this route, the rule expects it to say which outlets were measured, how many locations that covers, how many of them actually reported usable numbers, and what share of the group hit the disclosed result.

Forecasts. These project future performance instead of reporting the past. The rule doesn’t hand franchisors a checklist of exact facts to disclose for a forecast the way it does for historic data. Instead the franchisor has to give enough information, model assumptions, underlying studies, whatever it relied on, for a prospect to form an independent judgment about whether the forecast is reasonable.

If a franchisor skips Item 19 altogether, the FTC Rule has language for that too. The disclosure has to say, in substance, that the company does not make any representations about a franchisee’s future financial performance or the past performance of company-owned or franchised outlets, and that no employee or representative is authorized to make one either, written or spoken. If a sales rep tells you a number that isn’t in Item 19, that’s not a disclosure. It’s a violation, and it’s worth writing down exactly what was said and when.

Why some coffee brands disclose and others don’t

Roughly nine in ten franchise brands across all industries include some form of Item 19 data, based on a review of 171 brands compiled by FranchiseVS, though disclosure rates vary a lot by category. Coffee sits inside a food-and-beverage space where disclosure is common but far from universal.

Subway is the clearest non-coffee example of a large, mature chain that omits Item 19 financial performance data from its FDD entirely, according to franchise-data trackers reviewing its 2025 and 2026 filings. That absence doesn’t mean anything illegal is happening. It means Subway has decided not to make a legally binding numbers claim, which also means there’s nothing in the FDD you can hold them to later.

Reading non-disclosure as automatically suspicious isn’t quite right. A newer brand with only a handful of locations may not have enough reporting outlets to build a defensible historic FPR yet. A brand that had a bad stretch in a particular region might reasonably worry that a system-wide average would mislead in either direction. And some legal teams simply prefer to avoid the litigation exposure that comes with any FPR, reasonable basis or not.

What non-disclosure does mean is that you’re on your own for the number. You’ll be relying on franchisee interviews, your own market research, and independent sources like Franchise Chatter or FranchiseInvestorData that track filings even when the franchisor’s own document stays quiet. None of that carries the legal weight of a number the franchisor put in Item 19 and had to substantiate.

What the disclosure formats actually look like

There’s no single template. Three coffee brands with recent FDD filings show three different approaches, and comparing them side by side is a decent way to see how much the format itself shapes what you can and can’t conclude.

Scooter’s Coffee (2024 FDD). The disclosure covers 555 reporting kiosks and presents a system median AUV of $879,725, with a top-quartile AUV of roughly $1,268,540 and an associated top-quartile net margin of 20.45%, according to a review of the filing by FranchiseInvestorData. That’s a quartile-based format: instead of one average, you see where the top-performing 25% of locations land, which is more useful than a blended average because a handful of very strong stores can otherwise drag the overall number up.

7 Brew (2025 FDD). The reporting here is built around gross sales and a store-level margin figure. Average annual gross sales across franchised locations came in at $1,989,229, with an average store-level EBITDAR margin of 28.99%, per a review of the filing by BizFranHub. EBITDAR strips out earnings before interest, taxes, depreciation, amortization, and rent, which is a broader margin figure than plain net income and specifically excludes what is often a franchisee’s largest fixed cost.

Caribou Coffee (2025 FDD, covering 2024 fiscal year). This filing splits results by format instead of collapsing everything into one number. Non-traditional kiosk locations are broken out by venue type, for example grocery-store kiosks averaging $267,063 against airport kiosks averaging $1,836,096, while traditional Cabin locations (5 reporting franchises) averaged $681,311 and Chalet locations (2 reporting franchises) averaged $512,747, according to Franchise Chatter’s review. That’s an average/median/high/low format applied separately to each store type, which is more granular than a single system-wide number but also means some subsets are built on a very small handful of locations.

Here’s what those three approaches look like next to each other:

Brand (FDD year)	Disclosure format	What’s shown	Reporting base
Scooter’s Coffee (2024)	Median + top quartile	AUV and top-quartile net margin	555 kiosks
7 Brew (2025)	Average + margin	Gross sales and store-level EBITDAR	System-wide franchised locations
Caribou Coffee (2025, FY2024)	Average/median/high/low by format	Gross sales, split by kiosk venue type and store format	131 kiosks; 5 Cabins; 2 Chalets

Sources: Scooter’s Coffee, FranchiseInvestorData 2024 FDD review. 7 Brew, BizFranHub 2025 FDD review. Caribou Coffee, Franchise Chatter 2026 review of the 2025 filing.

Only Scooter’s ties a margin figure to a quartile, and only 7 Brew publishes a margin figure at all. None of the three publish franchisee net income after debt service, the number most people actually mean when they ask “how much would I make.”

What Item 19 cannot tell you

Even a generous, well-built Item 19 has real limits, and understanding them matters more than reading the top-line number.

It usually stops at revenue, not profit. Dunkin’s 2025 FDD is a useful example: its Item 19 discloses actual, historical AUVs (average unit volume, defined as gross sales) for defined groups of franchised restaurants, but it does not provide a simple net profit or owner-earnings figure, and it excludes labor, rent, royalties, debt service, and taxes from that presentation, per Franchise Chatter’s review of the filing. A location can show a strong AUV in Item 19 and still lose money once those costs come out, and Item 19 alone won’t show you which is true.

It can exclude entire regions or store types. Dunkin’s disclosure specifically does not make financial performance representations for restaurants in Alaska or Hawaii, or for APOD (alternative point of distribution, meaning non-traditional locations) restaurants, according to that same review. Any time an Item 19 carves out a region or format, ask why, and ask what the numbers look like for the carved-out group if the franchisor has them.

It reflects survivorship. A historic FPR is built from outlets open and reporting during the measured period. Locations that closed before that window don’t show up, so a system that’s had a wave of closures can still post a decent-looking Item 19 built entirely from the survivors.

Small subsets aren’t statistically stable. Caribou’s Chalet figure of $512,747 is built from two reporting locations, disclosed as such, but a two-location average moves a lot if either store has an unusual year. Compare that to Scooter’s 555-kiosk base and you’re looking at two very different levels of statistical weight, even though both are legitimate disclosures.

It cannot capture your specific deal. Your rent, your local labor market, your build-out cost, your debt terms, none of that is in a system-wide Item 19. The disclosure describes a population of stores, not the one you’d be signing a lease for.

How to actually read one

A few habits make Item 19 much more useful once you’re looking at an actual FDD:

Start with the measured group before you look at the number. How many outlets were open during the period, how many of those reported usable data, and what’s excluded. A disclosure built on 500-plus reporting locations and one built on five are not the same kind of evidence, even if the format looks similar on the page.

Separate revenue lines from margin lines. If a table says “average unit volume” or “gross sales,” that’s top-line. If it says EBITDAR, EBITDA, net income, or cash flow, that’s a margin concept, and you should note exactly which costs are excluded from it, because EBITDAR specifically leaves out rent.

Ask for the number the disclosure doesn’t show. If Item 19 stops at gross sales, the follow-up question for a franchisee call is straightforward: what’s the actual expense load. Our guide to questions to ask current and former franchisees has a longer list built around exactly this gap.

Read Item 19 next to Items 6 and 7, not by itself. The Item 19 revenue number means little without knowing the royalty percentage and ongoing fees from Item 6, and the upfront investment range from Item 7, sitting next to it. Our FDD walkthrough covers how those items connect.

Cross-check the filing year. Franchise disclosure documents update annually, and a number from a 2023 filing describes a different economy than one from 2025 or 2026. Always confirm which year’s data you’re looking at, and treat multi-year-old figures as historical context, not current reality.

If you’re comparing more than one brand’s Item 19 side by side, our coffee franchise comparison lays out cost and format differences across several brands in one place, which is a faster starting point than pulling each FDD cold.

The honest bottom line

Item 19 is genuinely useful, and it’s the only place in the entire FDD where you get anything close to real operating numbers. But it was built as a legal disclosure standard, not a buyer’s report card. The format varies by brand, the depth varies by brand, and the choice to disclose at all is entirely up to the franchisor.

Read it for what it actually says: which outlets were measured, over what period, in what format, and with what excluded. Then go build the rest of the picture yourself, through franchisee calls, your own local cost estimates, and a franchise attorney’s review before you sign anything. For the full sourcing approach behind figures on this site, see our editorial methodology.