Florida’s new operations-charge disclosure law took effect July 1, and every food service establishment in the state now owes new language on its menus, ordering apps, contracts, bills, and receipts. Senate Bill 606, signed into law on June 2, 2025 and codified at section 509.214 of the Florida Statutes, defines an “operations charge” as any automatic fee, other than a government-imposed tax, that a customer is required to pay in addition to the cost of the food and beverage, including service charges, automatic gratuities, delivery fees, and credit card surcharges. The law does not create a private right of action, so the enforcement path runs through state regulatory authorities rather than through customer lawsuits.
For Florida operators considering a sale in the next 24 months, and for the multi-market groups eyeing Florida expansion, this changes what a clean P&L looks like at diligence. The disclosure rules are mechanical, but they trace back into the receipt, the POS, and the way service-charge revenue flows on the income statement, and buyers will scan for both the compliance posture and the tenant-side operations-charge economics before writing an offer.
What § 509.214 Actually Requires
The disclosure is required in every place the customer sees the charge before the sale. Menus, written contracts, websites, and mobile ordering apps must state the amount or percentage of the operations charge and its purpose, in a font that is at least as large as the menu item descriptions. Establishments without menus or table service must post the notice on a menu board or a sign at the register. On the bill and every subsequent receipt, the operations charge must appear on its own line, separated from gratuity and sales tax, so the customer sees three distinct lines instead of one blended charge. If the operations charge includes an automatic gratuity, the automatic gratuity has to be broken out on the receipt as its own item.
The statute carves out one narrow exemption for prepaid dining plans, meal packages, and fixed-price offerings where the total price is disclosed in advance; every other Florida food service establishment is in scope. For a full-service brasserie, a fast-casual chain, a coffee shop, or a delivery-first operator, the compliance floor is the same starting July 1.
Where SB 606 Shows Up in Diligence
For a broker, the receipt line is where SB 606 matters, and buyers will scrutinize it three ways in Florida diligence. First, the top-line and the operating margin get compared differently by a Florida buyer. A blended service charge that never got broken out on the receipt made the P&L look one way to a buyer; a clean, separately stated operations charge shows a different picture side by side. Any buyer coming to a Florida seller after July 1 will want the last twelve months of receipts formatted the new way before underwriting the trailing P&L.
Second, the auto-gratuity accounting gets more transparent for anyone comparing the receipts to the P&L. Under SB 606, the auto-gratuity has to sit on its own receipt line when it lives inside the operations charge. That break-out makes the operator’s payroll flow visible to a buyer at the receipt level for the first time. Any diligence review will now compare the operations-charge revenue on the P&L against the reported wages paid through it, and if those don’t line up, the buyer will discount.
Third, the POS integration itself becomes a diligence item on its own. A Florida seller with an outdated POS that can’t cleanly separate the three receipt lines is a seller with a compliance risk baked into the operating platform, and that moves the SBA financing conversation, since lenders don’t love seeing a regulatory to-do list on the day of close.
Multi-Market Operators and the Florida Compliance Layer
For a Boston, New York, or California operator eyeing a Florida location, SB 606 is one more disclosure regime to plan for on top of what’s already live in the home market. For a Corbett client expanding out of the Northeast or the West Coast into South Florida, the practical consequence is that “operations charge” cannot be standardized as a top-line practice across states. Each POS rollout has to be per-market, and the finance team has to build receipt formats for the destination state before the location opens.
Jackson Lewis, in its SB 606 compliance advisory, recommends operators review current operations charge practices and determine how they are being communicated and distributed, update all affected materials to clearly indicate the existence of operations charges and the amount or percentage of the charge, and modify point-of-sale systems so receipts properly itemize and explain operations charges. That’s the compliance minimum, and a seller preparing for a listing conversation this fall should be past all three before the mock diligence.
Three Moves for Florida Operators Right Now
First, pull one of your current receipts and check it against the SB 606 checklist. Is the operations charge on its own line, separated from gratuity and sales tax, with the percentage or dollar amount visible? If the answer is no, that is a POS configuration change that should already be scheduled.
Second, audit the last twelve months of operations-charge revenue against your reported wages and ask your CPA to reconcile the two. If there is a gap (operations-charge revenue that isn’t clearly routing to a payroll line or a documented operating cost), clean it up before the next audit or the next diligence request.
Third, if a sale is on the horizon in the next twelve months, ask your broker for a mock diligence pass on the SB 606-formatted receipts. A buyer will pull three months of transaction data during diligence, and the seller who has already sanity-checked what those receipts show is the seller with a smoother path to close.
Cleaner Receipts, Cleaner Deals
The compliance conversation is the surface layer of what SB 606 changes. The real signal the statute sends into the Florida transaction market is a receipt that is, for the first time, machine-readable and comparable across sellers. That transparency will show up in offers within a quarter, and it will show up first in the way lenders and franchisor development teams underwrite Florida acquisitions. The operators who front-run this with clean receipts, clean CPA reconciliation, and clean POS integration will be the ones getting the tighter multiples when the sale conversation starts.
Sources
- ClickOrlando, “New Florida restaurant law takes effect this week” (2026-06-30)
- Holland & Knight, “Florida Enacts Disclosure Requirements for ‘Operations Charge’ at Food Service Establishments” (2025-06)
- Jackson Lewis, “On the Menu: Florida SB 606 Serves Up More Rigid Requirements for Restaurants to Disclose Operations Charges”
- Lowndes, “Florida SB 606: New Fee Disclosure Requirements for Food Service Establishments”
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