New Arizona Corporation Commission Policies Aim to Prevent Business Filing Fraud

Effective June 16, 2025, the Arizona Corporation Commission (AZCC) began implementing a series of new policies to protect business owners from unauthorized and fraudulent filings. These changes, approved unanimously by the Commission on May 8, 2025, aim to improve filing security while preserving accessibility for entrepreneurs and legal representatives. Certain features will roll out later in conjunction with the AZCC’s new online system.

Below is an overview of the new requirements and how they affect Arizona businesses.

1. Two Forms of Identification Now Required

To reduce fraud and verify filer identity, the AZCC will require two forms of ID when submitting filings in person. Filers may present either two primary forms or one primary and one secondary form of identification.

Accepted Primary ID Forms Include:

• Arizona driver’s license or state-issued photo ID

• U.S. passport or passport card

• Permanent Resident Card

• Real ID

• U.S. Military ID

• Tribal ID

• Employment Authorization Document with photo

Accepted Secondary ID Forms Include:

• W-2 form

• Birth certificate

• Voter registration card

• Health insurance card

• Fingerprint clearance card

• Paystub

Learn more from the AZCC Corporations Division: https://www.azcc.gov/corporations

2. New Optional LLC Signing Authority Form

To clarify who is authorized to file on behalf of an LLC, the AZCC now offers an optional Signing Authority Form. This form allows an LLC’s registered member or manager to designate another individual (such as a staff member or attorney) to act on behalf of the business.

This form must be completed in person with proper identification and will be retained by the AZCC to verify future filings. It does not restrict the authority of existing members or managers.

3. Annual Attestation of Existence for LLCs

To maintain up-to-date records and prevent misuse of dormant entities, the AZCC will now send electronic attestation notices to LLCs that have not filed any documentation in the previous two years. These LLCs must confirm continued activity by responding via the AZCC’s online portal.

If no response is received within 60 days, the AZCC will initiate administrative dissolution proceedings. The entity’s status will first be marked “pending inactive,” and if no action is taken within 120 days, dissolution will be completed.

More on administrative dissolutions and LLC maintenance: https://www.azcc.gov/corporations/faq#LLCs

4. Use of Custom Annual Report and Disclosure Forms

Corporations now have the flexibility to draft and submit their own Annual Reports and Certificates of Disclosure—provided the content meets statutory requirements and includes the AZCC’s Guidance Worksheet. This change is especially useful for attorneys and companies that maintain their own internal documentation standards.

If the required worksheet is not included with a custom form, the AZCC will reject the filing. As always, filers may continue using the AZCC’s standard forms if preferred.

You can access the official AZCC Guidance Worksheet here: https://www.azcc.gov/corporations/annual-reports

How Business Owners Can Get Ready

While not legally required, the following practical steps can help business owners and authorized representatives prepare for the AZCC’s new policies and minimize filing delays:

1. Verify Identification in Advance:

If you plan to file documents in person, confirm you have two valid forms of ID that meet the AZCC’s new standards.

2. Create an Online Account with the AZCC:

If your business was originally formed by someone else—such as a legal or filing service—you may not have direct access to the AZCC’s online portal.

• Visit https://ecorp.azcc.gov to set up an account using your preferred email address.

• In some cases, especially where the business was created by a third party, you may need to call the AZCC at (602) 542-3026 to verify your identity and request that your business be linked to your new online account.

• This step ensures that you—not just a service provider—receive important notifications, including LLC attestation requests and filing updates.

3. Check Your Business Record for Accuracy:

Search your entity at https://ecorp.azcc.gov/EntitySearch/Index and review your listed statutory agent, business address, and any contact email. If anything is outdated or missing, consider submitting an update.

4. Consider Submitting a Signing Authority Form (LLCs):

If someone other than a current member or manager is routinely filing on behalf of your LLC, completing a Signing Authority Form may help prevent future rejections.

5. Review Custom Filings for Compliance:

If you plan to submit your own version of the Annual Report or Certificate of Disclosure, download and use the AZCC Guidance Worksheet to ensure all statutory requirements are met.

6. Stay Informed with AZCC Resources:

Bookmark https://www.azcc.gov/corporations to stay current on filing procedures, system updates, and future rollout dates.

Final Reminders

These policies are designed to reduce fraudulent activity while preserving efficient access to business registration and compliance services in Arizona. Business owners and their representatives should be aware of the June 16, 2025 in-person effective date and stay alert for additional rollouts tied to the upcoming online system.

For personalized legal guidance or support with Arizona business filings, schedule a consultation here. 

1. https://www.azcc.gov