ACC Business Filing Changes: Key July 2025 Updates

Is your Arizona business ready for the new filing requirements?

The Arizona Corporation Commission (ACC) has adopted four significant policy changes aimed at enhancing fraud prevention and streamlining business filings. These changes will affect both LLCs and corporations operating in Arizona, as implementation began on June 16, 2025, for in-person filing. 

What to Expect: This post breaks down each new policy, explains who is affected, and provides a clear action plan to keep your business compliant. You’ll learn exactly what documents you need, which forms to file, and how to avoid potential filing rejections.

What’s Changed: Quick Reference Guide

Policy #1: Two Forms of ID Required

As of June 16, 2025, anyone submitting business filings in person at the ACC will need to present two forms of identification:

• Primary ID: Government-issued photo identification (driver’s license, passport, or state ID)
• Secondary ID: Social Security card, credit card, utility bill, or other supporting documentation

This requirement applies to business owners, registered agents, and third-party filing services. For filing runners or service companies, the ACC will require documentation confirming their authorization to file on behalf of the business.

Policy #2: Optional LLC Signing Authority Form

LLCs can now file a designated Signing Authority Form, which clearly establishes who has the legal authority to act on behalf of the company. While optional, this form offers several benefits:

• Prevents unauthorized changes to your LLC records
• Streamlines future filings by pre-establishing signature authority
• Particularly valuable for multi-member LLCs to avoid internal disputes
• Creates a clear record for banks, vendors, and other third parties

The form must be authorized by managing members or as specified in your operating agreement. Consider filing this form proactively before any disputes arise among members.

Policy #3: Attestation for Inactive LLCs

Beginning January 2026, the ACC will implement a tracking system for potentially inactive LLCs. Under this policy:

• The ACC will send notifications to LLCs that haven’t filed any documents in recent months
• Business owners must respond with an attestation that the entity is still active
• Non-responsive entities may be flagged as “potentially inactive” in ACC records
• After extended non-response, entities could face administrative dissolution

This policy aims to clean up Arizona’s registry of abandoned business entities. Set calendar reminders so you can respond promptly when notifications arrive.

Policy #4: Self-Drafted Reports & Disclosures for Corporations

The ACC is providing new flexibility for corporations by accepting self-drafted annual reports and disclosure documents, provided they contain all required information. Key points:

• Standard ACC forms remain valid and can still be used
• Custom forms must follow the ACC Guidance Worksheet (available on their website)
• All required disclosures must be included, regardless of the format
• Electronic submission guidelines remain unchanged

This change offers corporations more flexibility while ensuring all necessary information is still provided to the state.

Recommendations for Arizona Business Owners

To prepare for these changes, consider taking these steps:

• Gather acceptable identification documents if you plan to file in person
• Discuss with your business partners whether filing a Signing Authority Form makes sense for your LLC
• Update your contact information with the ACC to ensure you receive attestation notices
• Review your annual filing processes to determine if custom forms would benefit your corporation
• Consider consulting with a business attorney to ensure compliance with these new requirements

Where to Get More Information

The ACC will publish detailed guidance on its website closer to the implementation date. For specific questions about how these changes affect your business:

• Visit the ACC website 
• Call the ACC Business Services Division at (602) 542-3026
• Consult with a qualified business and tax law attorney

By understanding and preparing for these changes now, you can ensure your business maintains compliance and avoids unnecessary complications when the new policies take effect.

Take Action Now

Don’t wait until the June deadline approaches. Review your current filing processes, gather necessary identification documents, and consider whether the new optional forms would benefit your business structure. If you have questions about how these ACC business filing changes might impact your specific situation, contact Sorrell Business & Tax Law today for personalized guidance.