The Arizona Corporation Commission (ACC) has announced major changes to its business filing procedures aimed at preventing fraud and safeguarding business owners from unauthorized filings. On May 8, 2025, the Commission unanimously approved four new policies that will affect how Arizona limited liability companies (LLCs), PLLCs and corporations file and manage their records with the ACC.

These updates are part of a broader effort to protect the integrity of Arizona’s business environment while still making it easier for entrepreneurs and business owners to stay in compliance. Here’s a breakdown of the new policies and what they mean for your business.

New Policy 1: Two Forms of ID Required to File a Document

To strengthen identity verification and prevent fraudulent filings, anyone submitting any document to the ACC on behalf of a business must present two forms of identification.

Acceptable ID combinations:

  • Option 1: One Primary ID + One Secondary ID
  • Option 2: Two Primary IDs

Primary IDs include:

  • Arizona driver’s license or state ID
  • Real ID
  • Passport or Passport Card
  • U.S. Military ID
  • Permanent Resident or Employment Authorization Card with photo
  • Tribal ID

Secondary IDs include:

  • W-2 form
  • Voter registration card
  • Birth certificate
  • Health insurance card
  • Fingerprint clearance card
  • Recent pay stub

Effective Date for ID Policy:

  • In-person filings: January 3, 2026
  • Online, mail, and fax filings: January 3, 2026

Note: Law firms and service companies using authorized representatives (“runners”) will follow a different identity verification process.

Practical Note:  KEYTLaw, LLC, is an authorized representative, i.e., a “runner”) that can file documents with the Arizona Corporation Commission without submitting anybody’s IDs.  Hire us to form your Arizona LLC or amend its Articles of Organization so you do not have to submit two forms of ID to the Arizona Corporation Commission.

New Policy 2: New Signing Authority Form for LLCs & PLLCs

LLC and PLLC members and managers can now designate who is allowed to sign on behalf of the company by completing and delivering a Signing Authority Form to the Arizona Corporation Commission.

  • Only current, registered LLC members or managers may submit this form.
  • Must be filed in person with valid ID and in the presence of ACC staff.
  • This form does not limit the authority of existing members or managers; it simply adds named individuals as authorized signers for future filings.

Effective Date:

  • In-person: January 3, 2026
  • Online, mail and fax filings: January 3, 2026

Practical Note:  If we form your new Arizona LLC or PLLC we can also file a Signing Authority Form with the Arizona Corporation Commission that designates the members of your companyy that have the authority to file documents that affect the company.

New Policy 3: LLCs & PLLCs Must Periodically Notify the ACC that They Exist

To maintain accurate records and reduce fraudulent “zombie” LLCs, the ACC will require businesses to confirm their ongoing existence to the ACC.

Each January, LLCs that have not filed anything with the ACC for two years will receive an email notification. The business owner or statutory agent must confirm the LLC is still active by clicking a button in the ACC’s online portal.  Important:  Make sure the ACC always has a current email address for the LLC.

If no response is received within 60 days, the LLC will be labeled “pending inactive,” and the ACC will begin a 120-day process to administratively dissolve the company.

Effective Date:

  • January 3, 2026

New Policy 4: Corporations Can Use Their Annual Report Forms If They Meet the Rules

Corporations will have the option to use their own versions of the Annual Report and Certificate of Disclosure forms—but only if:

  • The forms meet all statutory requirements, and
  • A completed ACC Guidance Worksheet is submitted with them.

Without the worksheet, custom filings will be rejected. Businesses may still choose to use the official ACC forms.

Effective Date:

  • In-person, mail, fax, and online: January 3, 2026

What These Changes Mean for You

These new policies are designed to:

  • People who file a document with the Arizona Corporation Commission must submit two forms of ID
  • Increase protection against fraud and unauthorized filings
  • Improve the accuracy of business records
  • Make filing and compliance more secure for all Arizona businesses

Hire KEYTLaw, LLC to form an LLC, PLLC or Corporation or File a Document with the Arizona Corporation Commission So You Don’t Have to Give the ACC 2 Forms of ID

  • Hire us to form one or more new Arizona LLCs or PLLCs by submitting our online formation questionnaire at https://azllc.com/llcq.
  • Hire us to document the the addition or removal of one or more members or managers of an LLC by submitting our questionnaire at https://azllc.com/changeq
  • Hire us to prepare and file an Amendment to the Articles of Organization of an LLC or PLLC by submitting our amendment questionnaire at https://www.keytlaw.com/azllclaw/aaoo-q

Have Questions for the ACC?

📧 Email: [email protected]
📞 Call Center: (602) 542-3026
📞 Toll-Free (Arizona Only): 1 (800) 345-5819

Stay informed and make sure your LLC or corporation is prepared for these important changes.

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