Breaking News! The Arizona Corporation Commission (ACC) has announced new business filing policies, many of which went into effect Monday, June 16, 2025!
The ACC and its Corporations Division believe the four (4) new policies outlined below will help prevent unauthorized filings and deter business fraud, while also maintaining streamlined customer experiences. In adopting these new policies, the ACC is attempting to strike a balance between protecting the interests of business owners, while avoiding an overly burdensome compliance process.
The four (4) new policies, and the specifics on their effective dates, are as follows:
Policy 1 – Two Forms of ID Required when Filing:
When filing on behalf of a business, individual filers will now be required to present two (2) forms of identification* as follows:
- One (1) “Primary Form” AND one (1) “Secondary Form,” or
- Two (2) “Primary Forms.”
Acceptable Primary Forms of ID:
- State-Issued Driver’s License,
- State-Issued Photo ID,
- Real ID,
- Passport or Passport Card,
- Permanent Resident Card,
- Employment Authorization Document with Photo,
- S. Military ID, or
- Tribal ID.
Acceptable Secondary Forms of ID:
- Form W-2,
- Birth Certificate,
- Voter Registration Card,
- Fingerprint Clearance Card,
- Health Insurance Card, or
- Pay Stub.
* A different procedure will apply for verifying the identity of any service company filers and law firm “runners.”
Effective Dates for Policy 1:
- In-person filings: June 16, 2025
- Online, fax and mail filings: TBA (to be implemented in conjunction with the ACC’s new online filing system scheduled to launch later this year).
Policy 2 – “Signing Authority Form” for LLCs:
LLCs will now be offered the option to submit a “Signing Authority Form” to help ensure that only properly authorized persons can sign on behalf of the LLC.
This Signing Authority Form may be submitted ONLY by an existing and registered member or manager of an LLC; and in the case of currently existing LLCs, the Signing Authority Form may be completed and submitted ONLY:
- In person,
- With proper identification provided, and
- In the presence of ACC staff.
Once submitted, this Signing Authority Form will be validated against all subsequent business filings of the LLC.
The sole purpose of this Signing Authority Form is for an LLC to designate what person(s), OTHER THAN existing members or managers, may sign on behalf of the LLC. It is not intended, and may not be used, to limit the ability of any member or manager to sign on behalf of the LLC.
Effective Dates for Policy 2:
- In-person filings: June 16, 2025
- Online filings: TBA (to be implemented in conjunction with the ACC’s new online filing system scheduled to launch later this year).
Policy 3 – “Attestation of Existence” for LLCs:
Beginning in January 2026, and each January thereafter, the ACC’s Corporations Division will identify all LLCs that have failed to make any filings with the ACC in the preceding two (2) years. The ACC will send electronic notices to all such LLCs.
These notices will be sent to the statutory agent and/or owner(s) of each LLC and will require an electronic response from the recipient(s) to confirm the LLC remains in existence and continues the active conduct of business. The response required by the ACC will be simple, such as merely clicking a “respond” button through the ACC’s online portal.
If an LLC fails to provide a response to the ACC within sixty (60) days, the commission will proceed with an administrative dissolution of that LLC for failing to keep current its statutory agent and/or principal address information. Once such dissolution process is initiated, the LLC’s status in the ACC records will be changed to “pending inactive” until the 120-day administrative dissolution process is completed.
Effective Date for Policy 3:
- Online filings: TBA (to be implemented in conjunction with the ACC’s new online filing system scheduled to launch later this year).
Policy 4 – Filers May Use Their Own Annual Report and Certificate of Disclosure Forms:
As an option, corporations will now be allowed to submit their own self-drafted Annual Report and Certificate of Disclosure forms, but ONLY IF such forms:
- Satisfy all statutory requirements, and
- Are submitted along with the ACC’S Guidance Worksheet.
The purpose of the Guidance Worksheet is to ensure that any self-drafted Annual Report and/or Certificate of Disclosure forms comply with all statutory requirements. The ACC will reject any self-drafted Annual Report and Certificate of Disclosure forms that are submitted without the Guidance Worksheet.
All filers may continue to utilize the Annual Report and Certificate of Disclosure forms drafted and provided by the ACC.
Effective Dates for Policy 4:
- In-person filings: June 16, 2025
- Online, fax and mail filings: June 16, 2025
As always, please do not hesitate to reach out to our office for questions or assistance with any of these new ACC policies! We are here for you!
