New California Secretary of State Access Requirements for Third-Party Filings
The California Secretary of State has changed how third parties may access its online systems to submit filings on behalf of business entities.
The change is relevant to corporations and limited liability companies formed in California, as well as such entities formed outside California and registered to do business in California, that rely on attorneys, accountants, or other advisors to submit statutory filings.
Effective July 1, 2026, an entity must grant a third party “Full Access” to its California Secretary of State account before that third party may submit certain filings on the entity’s behalf. Previously anyone was able to submit filings online on behalf of an entity without providing prior authorization. In addition, many documents, such as terminations/dissolutions, could only be processed via physical paper filings, which created processing backlogs and wait times. In an attempt to reduce fraudulent filings and expedite other filings, the Secretary of State has now locked down certain filings for those who have Full Access only. Full Access on the California Secretary of State’s bizfile Online portal[1] allows an authorized user of a business entity to perform certain online transactions, such as Statement of Information filings, conversions and terminations/dissolutions, but only once they have verified their authority with the entity-specific PIN which is mailed to the entity’s last known mailing address.
Filings that currently require Full Access include:
Domestic Limited Liability Companies
• Statement of Information
• Amendment or Attachment to Statement of Information
• Certificate of Dissolution
• Certificate of Cancellation
• Short Form Cancellation Certificate
• Conversion/Merger Filings
Foreign Limited Liability Companies
• Statement of Information
• Amendment or Attachment to Statement of Information
• Certificate of Cancellation
• Conversion/Merger Filings
Domestic Corporations
• Statement of Information
• Amendment or Attachment to Statement of Information
• Certificate of Election to Wind Up and Dissolve
• Certificate of Dissolution
• Short Form Dissolution Certificate
• Nonprofit Certificate of Election to Wind Up and Dissolve
• Nonprofit Certificate of Dissolution
• Nonprofit Short Form Dissolution Certificate
• Conversion/Merger Filings
Foreign Corporations
• Statement of Information
• Amendment or Attachment to Statement of Information
• Certificate of Surrender
• Conversion/Merger Filings
How to Grant a Third Party Full Access to CA SOS Account
Obtaining the entity’s unique personal identification number, or PIN, is the first step in granting Full Access. To obtain a PIN for Full Access to an entity’s records, one will need to visit the California Secretary of State’s bizfile Online portal and log in or create an account. The account holder will then search for the entity, select its business record, and select the “Request Access” icon at the bottom of the entity’s profile panel. If the entity has not previously granted anyone access, the state will generate a unique PIN, which will be mailed to the entity’s last known mail address listed on the bizfile Online portal. Once this PIN is received, the account holder will log back into its bizfile account, search for and select the entity, and go back to the “Request Access” icon. The account holder then inputs the PIN to verify authorization and unlock full access to the entity’s records and available online filing functions. With Full Access, one is able to “Manage Full Access” which allows the account holder to assign access control to other users.
What Businesses Should Do Now
Businesses should review who currently has access to their California Secretary of State accounts and determine whether any attorneys, accountants, or other advisors will need Full Access to submit filings on their behalf.
Entities should address these access requirements well in advance of any filing deadline or transaction closing. Delays in obtaining a PIN or granting access could affect the timely submission of required filings or the entity’s ability to provide evidence of good standing in connection with a transaction.
We will continue to monitor developments related to these requirements. In the meantime, please contact Peter Wang or Lori Sudowe with any questions.