California Secretary of State Implements New Filing Access Requirements for Third Party Filings

Effective July 1, 2026, the California Secretary of State (CA SOS) has changed the way that businesses can file certain documents with the CA SOS.  These changes will impact any corporations and limited liability companies which use third parties such as attorneys or accountants to file their annual statements of information, as well as certain other specified documents.

Under the new rules, before the third party can submit any of the filings listed below, an authorized user on the business’s account must go to the business’s online CA SOS account and give their attorney, CPA, or other a third party which regularly makes filings for the business “Full Access” to the CA SOS bizfile online account.   Previously, it was common for law offices and other authorized third parties to submit these filings online without any requirement that the business give advance notice or confirmation of authorization to the CA SOS.

While the change is intended to reduce fraudulent filings with the CA SOS and speed up processing time for the filings, it has the potential to cause delays in filings for businesses which regularly use third parties such as their attorneys to make these filings.

What Businesses Should Do

Businesses should review their current CA SOS access and determine which attorneys, accountants, or other advisors need Full Access to file documents on their behalf.  If you do not have a PIN to access your CA SOS account, you may follow the directions below to obtain a PIN.

Businesses should complete the process of granting Full Access to any necessary advisors well before any filing deadline or other event that would require updated documents to be filed with the CA SOS.  Obtaining the necessary PIN to grant Full Access may take time, and delays could result in late filings or difficulties obtaining evidence of good standing needed for a transaction.

Should you have any questions or need assistance creating an account or establishing Full Access with the California Secretary of State, please do not hesitate to contact the authors or your usual counsel at Atkinson, Andelson, Loya, Ruud & Romo.

Filings Requiring Full Access

The following filings either currently require, or will soon require, Full Access for Domestic and Foreign LLCs, Corporations and Nonprofits:

  • Statements of Information and amendments
  • Dissolution and cancellation filings
  • Conversion and merger filings

How to Grant Full Access to Third Parties

The business must first obtain its unique entity PIN, which the CA SOS will mail to the entity’s last known mailing address.

To request and activate Full Access:

  1. Log in to or create an account on the CA SOS bizfile Online portal at the following link: CA Secretary of State - Sign In.
  2. Search for and select the business entity.
  3. Select “Request Access.”
  4. The CA SOS will mail the entity’s unique PIN to its last known mailing address if no one has previously been granted access.
  5. Once the PIN is received, enter it through the bizfile Online account to verify authorization and activate Full Access.

The person with Full Access can then use “Manage Full Access” to grant access to other authorized users, such as attorneys or accountants

This AALRR publication is intended for informational purposes only and should not be relied upon in reaching a conclusion in a particular area of law. Applicability of the legal principles discussed may differ substantially in individual situations. Receipt of this or any other AALRR publication does not create an attorney-client relationship. The Firm is not responsible for inadvertent errors that may occur in the publishing process.

© 2026 Atkinson, Andelson, Loya, Ruud & Romo

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