COMPARATIVE ANALYSIS OF FRANCHISING PRACTICES IN DEVELOPING COUNTRIES

Abstract

This article presents a comparative analysis of franchising practices in five developing countries – Malaysia, Brazil, China, South Africa, and Nigeria – with the aim of identifying distinguishing features, institutional frameworks, and developmental dynamics of the franchising industry across different economic and regulatory contexts. The study draws upon empirical data, sectoral reports, and academic literature to assess the scope and scale of franchising systems in each country, examining indicators such as the number of franchise brands and outlets, contribution to GDP, employment generation, legal foundations, and government support mechanisms. The research identifies notable similarities in the technical structuring and implementation of franchising business models, particularly in terms of operational formats, branding strategies, and mechanisms of franchisee engagement. However, significant differences are observed in the regulatory environments and the maturity levels of franchising markets. China, Brazil, and Malaysia represent countries with relatively saturated franchising sectors and robust legislative frameworks, characterized by high levels of formalization and active involvement of professional associations and state institutions. In contrast, South Africa and Nigeria are experiencing emergent franchising activities, marked by partial or absent sector-specific regulation and relatively fragmented institutional support. The African markets demonstrate high potential for international brand expansion, driven by demographic growth, rising consumer demand, and evolving middle-class segments. The study also emphasizes the role of national development strategies, such as Malaysia’s Franchise Development Plan and China’s evolving legislative instruments, in fostering transnational franchising competitiveness. The conclusions drawn from this study may assist policymakers, investors, and practitioners in designing targeted interventions to strengthen the franchising sector in emerging and transitioning economies.