BUSINESS LAW – ACC’s New Fraud-Fighting Policies You Need to Know

February 3, 2026

BY JAMES P. O’SULLIVAN, MAY LU & BRENDYN EDWARDS

If your entity is formed or registered to do business in Arizona with the Arizona Corporation Commission (ACC), the ACC recently added new tools to your business filing toolkit—and they are all about protection, prevention, and peace of mind.

On January 12, 2026, the ACC will launch its new filing portal named Arizona Business Connect to replace eCorp, which will include new features such as the ability to track the status of a filing, cancel a pending document, and submit online restructuring documents like a statement of conversion. In addition, on May 8, 2025, the ACC unanimously approved four new policies designed to reduce fraudulent filings and better safeguard Arizona corporations and limited liability companies (LLCs), some of which are effective now:

DOUBLE ID, DOUBLE SECURITY

Effective as of June 16, 2025, anyone filing in person on behalf of a corporation or LLC needs to show two forms of identification to ensure that the filer is actually authorized to do so. You can satisfy this requirement by presenting either (i) two Primary IDs (such as a passport, state-issued driver’s license, state-issued photo ID, permanent resident card, employment authorization document with photo, U.S. Military ID, or Tribal ID) or (ii) one Primary ID and one Secondary ID (such as a W-2 form, birth certificate, voter registration card, fingerprint clearance card, health insurance card, or pay stub).

For online, fax, and mail filings, the ID requirements will take effect later—timed with the launch of Arizona Business Connect.

WHO CAN SIGN FOR AN LLC? LET THE ACC KNOW

If you are owner of an LLC and want someone other than your registered members or managers to sign documents on the LLC’s behalf, you have the option of completing the new LLC Signing Authority Form. This form does not take away authority from current members or managers; it just expands who can sign. Once filed, the ACC will use this document to validate all future filings.

Currently, if you want to exercise this option, you will need to submit the Signing Authority Form in person, with a valid ID, in front of ACC staff. However, once Arizona Business Connect is live, you will be able to submit the form online.

STILL ACTIVE? PROVE IT

Here is a gentle nudge to all the “quiet” LLCs out there: if you have not submitted any documents to the ACC for filing within the last two prior years, the statutory agent and/or business owners of the LLC will be receiving an email check-in request from the ACC each January beginning in January 2026. You will have to then respond to this request by clicking a response button through Arizona Business Connect to verify that your LLC still exists and is actively doing business.

If the LLC is no longer conducting business, the LLC will be presented with options for voluntarily terminating the LLC. If no one responds within 60 days of the request, your LLC will be marked “pending inactive” on the ACC and the administrative dissolution process will begin.

Still no word after 120 days? Your LLC will be administratively dissolved, which will require you to apply for reinstatement within six years to keep your LLC active. This new policy allows the ACC to remove abandoned and fraudulent entities, freeing up those names for new active LLCs. However, we understand that the ACC is currently considering changing its policy regarding what happens if there is no response.

DIYers, REJOICE (BUT READ THE FINE PRINT)

For those who prefer to draft their own Annual Reports and Certificates of Disclosure, the ACC is giving you more freedom—with a guardrail. Effective as of June 16, 2025, filers may now submit their own customized versions of these documents as long as they meet all legal requirements and are accompanied by the ACC’s new Guidance Worksheet. If the worksheet is not included, the ACC will reject the filing. Of course, if you would rather use the ACC’s forms of Annual Report and Certificate of Disclosure, you can continue to do so.

A SMARTER, SAFER FILING EXPERIENCE

While these new policies add some steps, they, along with the new filing portal, are designed to streamline the filing process and improve customer experience while cracking down on fraud in a way that is minimally intrusive but meaningfully effective.

If you do any ACC filings, now is the time to confirm who can submit a filing on behalf of your entity, to review your entity’s status, and to decide whether you want to take advantage of any of these new features and functionalities.