Arizona Corporation Commission Launches New Policies to Prevent Business Filing Fraud

Business Law and Compliance

Updated June 2025 | Business Law & Compliance

The Arizona Corporation Commission (ACC) has adopted four new policies aimed at reducing fraudulent business filings and increasing protections for business owners. These reforms, approved unanimously on May 8, 2025, will roll out starting this summer, with additional implementation steps tied to the launch of the ACC’s new online filing portal later this year.

Here’s what Arizona business owners need to know.

Summary of the New Filing Policies

  1. Two forms of identification are now required for anyone filing on behalf of a business.

  2. LLCs can submit a Signing Authority Form to designate authorized signers.

  3. LLCs that haven’t filed in two years must confirm continued existence to avoid dissolution.

  4. Corporations may submit their own Annual Reports and Certificates of Disclosure, with a required guidance worksheet.

Policy 1: ID Requirements for Business Filings

Beginning June 16, 2025, individuals filing documents on behalf of a business must present two forms of ID:

  • One primary ID (e.g., driver’s license, passport, tribal ID), and

  • One secondary ID (e.g., voter card, paystub, health insurance card),
    or

  • Two primary IDs.

This policy applies to all in-person filings. Online, fax, and mail filings will follow once the ACC’s new online filing system goes live later this year. Runners representing law firms or service companies will follow a separate verification process.

Policy 2: Signing Authority Form for LLCs

LLCs can now submit a Signing Authority Form to formally designate who is allowed to sign future business filings on behalf of the company. Only an existing, registered member or manager may complete the form, and it must be filed in person with valid ID.

The form does not limit a manager’s or member’s authority, but it adds an extra layer of clarity and control. Once submitted, the ACC will validate future filings against this record.

This option is available in person starting June 16, 2025. Online submission will become available with the rollout of the new filing system.

Policy 3: Attestation of Existence for Dormant LLCs

Starting in January 2026, the ACC will begin sending electronic notices to LLCs that have not filed anything in the prior two years. The LLC’s statutory agent or principal will be asked to confirm whether the entity is still active via a simple response in the online portal.

If no response is received within 60 days, the LLC’s status will change to “pending inactive,” and administrative dissolution will begin after 120 days.

This change is designed to help clean up abandoned or inactive entities from Arizona’s business registry.

Policy 4: Self-Drafted Annual Reports and Disclosures

Businesses now have the option to submit their own versions of the Annual Report and Certificate of Disclosure, as long as the filings:

  • Comply with statutory requirements, and

  • Are accompanied by the ACC’s official Guidance Worksheet.

Filings without the completed worksheet will be rejected. Standard ACC-provided forms will remain available for those who prefer a simpler route. This policy applies to all filing methods effective June 16, 2025.

Key Effective Dates

Policy In-Person Filing Online Filing

Two Forms of ID June 16, 2025 TBD
Signing Authority Form June 16, 2025 TBD
Attestation of Existence N/A January 2026
Custom Annual Reports June 16, 2025 June 16, 2025

What Arizona Business Owners Should Do Now

  • Confirm that your business contact information is current with the ACC.

  • If you file in person, prepare two valid forms of ID.

  • Consider submitting a Signing Authority Form if your business uses external signers.

  • Review whether your current annual report process meets statutory compliance.

  • Stay informed about the launch of the new ACC online portal.

How the Tyler Allen Law Firm Can Help

We regularly assist Arizona businesses with compliance, filings, and formation matters. If you’re unsure whether these new requirements affect you—or want help getting ahead of the changes—our attorneys can help with:

  • Preparing ID documents or forms

  • Filing or updating your Signing Authority Form

  • Drafting compliant Annual Reports and Certificates of Disclosure

  • Responding to future attestation notices

Contact us today to schedule a compliance review or to get support with upcoming filings.

business law, ComplianceMelanie JorgensenBusiness Law, Compliance