Why This List Exists and Who It Is Written For
Search for state commercial financing disclosure law and you land on law-firm advisories, written for a bank or fintech's general counsel, dense with statutory citations and short on the one question an MCA broker actually has: does this change what I can say in my marketing, and do I need to register somewhere before I make another call? This page answers that question, state by state, sourced to the same law-firm trackers (Venable and Alston Consumer Finance) that most of this research draws from, but organized for the person running outbound, not defending a lawsuit.
This is not legal advice. It is a starting point for a conversation with your own counsel, built from public, dated sources, and it will go stale. Treat every effective date below as something to verify directly against the state statute before you rely on it for a specific campaign.
The 11-State Table
Most of these laws require a "provider" (often defined to include brokers) to give a standardized disclosure before a commercial financing transaction closes: total cost, payment schedule, and in several states now, an APR-equivalent figure. Where a state also requires registration, that is noted separately, since registration and disclosure are two different compliance obligations that get conflated in casual conversation. The full table, sourced to Venable and Alston, runs further down this page.
The Two Deadlines to Put on Your Calendar Now
Of the eleven, two changes are close enough to matter for a campaign you are planning today. California's SB 362 takes effect January 1, 2026 and adds an APR-equivalent disclosure requirement plus new restrictions on using the words "rate" and "interest" in commercial financing offers of $500,000 or less, on top of the state's existing disclosure law that has applied since December 9, 2022. If your marketing copy or sales scripts use either word loosely when describing an MCA's cost, that is worth a direct look before the new year, not after a complaint.
Texas HB 700 took effect September 1, 2025 and carries no de minimis exemption, meaning the usual 5-transaction carve-out other states allow does not apply here. Brokers and providers operating in Texas have until December 31, 2026 to complete registration, and the Office of Consumer Credit Commissioner can enforce up to $10,000 per violation. That registration deadline is the single most concrete near-term action item on this whole list.
The Missouri Date Discrepancy, Stated Honestly
One entry in this table is genuinely unsettled in the public record: Alston Consumer Finance lists Missouri's effective date as February 28, 2025, while Venable's tracker lists August 28, 2024, for what appears to be the same broker-registration requirement. Both are reputable law-firm trackers, and this research did not find a primary state source that resolves the conflict cleanly. Rather than pick one and present it as fact, the honest answer is: if you have Missouri exposure, verify the exact effective date directly against the Missouri statute or with counsel before you treat either date as settled. A tracker that quietly picks the more convenient of two disagreeing sources is worse than one that says plainly it does not know.
What "5-Transaction De Minimis Exemption" Actually Means
Most of the eleven states exempt a provider or broker who completes fewer than five commercial financing transactions in a 12-month period from the full disclosure requirement, on the theory that occasional, small-scale activity does not carry the same consumer-protection stakes as a business built around it. Louisiana, the newest state on this list (effective August 1, 2025), was the first to pass a law with no de minimis exemption of any kind, by entity type or dollar amount. Texas HB 700 followed the same no-exemption approach. If you operate at any real volume, in other words, "I only do a few deals a year" is not a reliable exemption in either state, and it is worth checking whether it still is in the others before you lean on it.
Reading the Table Correctly: Disclosure vs Registration
Two separate obligations show up across these eleven states, and they do not always travel together. Disclosure requirements govern what you have to tell a merchant about the cost of financing before the deal closes. Registration requirements govern whether you, as a broker or provider, have to sign up with a state agency before you can legally operate there at all, sometimes with an annual renewal (Connecticut, Utah) and sometimes with a one-time filing tied to a deadline (Texas). A state can have one without the other, or both. Read each state's entry for which obligation actually applies to your role, broker versus provider, rather than assuming the word "disclosure law" covers everything a given state requires.
How to Use This Page
- Find every state where you or your ISO actively market or close deals, not just where your company is incorporated.
- For each one, check whether a disclosure requirement, a registration requirement, or both apply to your role.
- Flag any state with a de minimis exemption you have been relying on, and confirm your actual transaction volume still qualifies.
- Put California's January 1, 2026 date and Texas's December 31, 2026 registration deadline on a calendar today, not on a list to revisit later.
- Verify every date in this table against the primary state statute or your own counsel before treating it as final. Laws in this space are still actively changing.
| State | Effective Date | What to Know | De Minimis Exemption |
|---|---|---|---|
| California | Dec. 9, 2022 (SB 362 adds new rules effective Jan. 1, 2026) | SB 362 adds an APR-equivalent disclosure requirement and restricts "rate" / "interest" language for offers of $500,000 or less. | Standard 5-transaction exemption applies to the base law |
| Connecticut | July 1, 2023 | Brokers register annually and are defined as a "provider" under the law. | Standard 5-transaction exemption |
| Florida | July 1, 2023 | A "provider" is defined as completing 5 or more transactions per year. | Built into the "provider" definition itself |
| Georgia | Jan. 1, 2024 (SB 90, enacted 2024) | Brokers are included in marketplace-lending arrangements covered by the law. | Standard 5-transaction exemption |
| Kansas | July 1, 2024 | The Kansas Commercial Financing Disclosure Act. | Standard 5-transaction exemption |
| Louisiana | Aug. 1, 2025 | The first state law with no de minimis exemption at all, by entity type or dollar amount. | None |
| Missouri | Feb. 28, 2025 (Alston) or Aug. 28, 2024 (Venable), sources disagree | Broker registration required. Verify the exact effective date directly before relying on it. | Standard 5-transaction exemption (per available sources) |
| New York | Aug. 1, 2023 (CFDL enacted 2023) | The Commercial Finance Disclosure Law explicitly includes brokers in its "provider" definition. | Standard 5-transaction exemption |
| Texas | Sept. 1, 2025 (HB 700) | No de minimis exemption. Broker and provider registration due Dec. 31, 2026. OCCC enforcement up to $10,000 per violation. | None |
| Utah | Jan. 1, 2023 | Annual registration required with the Utah Department of Financial Institutions. | Standard 5-transaction exemption |
| Virginia | July 22, 2022 | Providers must register; brokers are implied under the law. | Standard 5-transaction exemption |
Sourced from Venable LLP and Alston Consumer Finance state-by-state trackers, current as of this page's publish date. This is not legal advice. Verify every date and requirement against the primary state statute or your own counsel before relying on it.
What this means for you
- Eleven states now regulate commercial financing disclosures in a way that reaches MCA transactions: California, Connecticut, Florida, Georgia, Kansas, Louisiana, Missouri, New York, Texas, Utah, and Virginia.
- California SB 362 (effective Jan. 1, 2026) and Texas HB 700's Dec. 31, 2026 broker registration deadline are the two nearest-term actions on this list.
- Louisiana and Texas are the only two states with no de minimis exemption. Every other state on this list carves out roughly 5 transactions per 12 months.
- The Missouri effective date is genuinely disputed between two reputable trackers (Alston vs. Venable). Verify it directly rather than trusting either source blindly.
Sources
The external data in this guide draws on the sources below. Figures described in the text as estimates or industry triangulations are directional and are not attributed to a single dataset.
- Venable LLP, state commercial financing disclosure laws (March 2026)
- Alston Consumer Finance, commercial financing disclosure requirements and exemptions
- Buchalter, California SB 362 rate and interest restrictions starting January 1, 2026
- Venable LLP, Missouri commercial financing disclosure law (August 2024)