How the Count Went From Two States to Eleven
By the end of 2022, two states had an operative commercial financing disclosure law: California, under its original SB 1235 framework, effective December 9, 2022, and Virginia, effective July 22, 2022. That count is calculated from the per-state effective dates published by Alston Consumer Finance and Venable LLP, the two firms that maintain the closest thing this space has to a standing legal tracker.
By the end of 2023 the count had tripled to six states, with Utah (January 1, 2023), Connecticut (July 1, 2023), Florida (July 1, 2023), and New York (August 1, 2023) all going live within a single calendar year. Two more states, Georgia (January 1, 2024) and Kansas (July 1, 2024), brought the total to eight by the end of 2024.
Three States Joined in 2025 Alone
2025 added three more states, bringing the total to eleven. Missouri’s exact effective date carries a documented disagreement between the two source firms cited above: Alston Consumer Finance dates it February 28, 2025, while Venable LLP dates it August 28, 2024, a discrepancy neither firm has publicly reconciled, so treat “Missouri, 2025” as directionally correct rather than a single confirmed date. Texas followed on September 1, 2025 under HB 700, with broker and provider registration required by December 31, 2026 and Office of Consumer Credit Commissioner enforcement of up to $10,000 per violation.
Louisiana, effective August 1, 2025 per the same sources, is the state that broke the pattern the other ten states share. Every other state on this list carves out some kind of de minimis exemption, commonly five transactions per twelve months, before the disclosure requirement applies. Louisiana is described as not having one: reported as the first state with no de minimis exemption at all, by entity type or dollar amount, meaning even a single Louisiana transaction can trigger the law’s requirements.
That specific claim, no de minimis exemption at all, carries a real caveat: the exact effective date and the precise transaction-count threshold that defines a covered “provider” under Louisiana’s law show some disagreement across the sources this research pass found, and neither was independently confirmed against the Louisiana Legislature’s own enrolled bill text. Treat “Louisiana, zero exemptions” as the reported reading, not a fully re-verified one, before repeating it as settled fact.
California’s SB 362 Is a Different Kind of Growth
Not every entry on this timeline is a new state joining the list. California’s SB 362, effective January 1, 2026, is the first documented case of a state tightening a disclosure law it already had rather than a new state adopting one for the first time, a second growth dimension alongside the raw state count, per legal-compliance publisher Cloudsquare’s coverage of the amendment.
Under SB 362, once a specific financing offer is made, any subsequent communication that states pricing, a fee, or a financing amount must simultaneously disclose the Annual Percentage Rate, turning what used to be an ordinary follow-up call into a regulated disclosure moment. The law also restricts describing non-APR pricing using “rate” or “interest” language, meaning calling a factor a “rate” or a fixed fee “simple interest” can itself be treated as deceptive.
Why the Trend Line Matters More Than Any Single State
Read year by year, the pattern is not a handful of unrelated state actions, it is an accelerating trend: two states in 2022, four more by 2023, two more by 2024, three more in 2025, and the first tightening amendment to an existing law in 2026. Each new year has added either more states or more depth to states already covered, never neither.
For a broker or ISO operating across state lines, that trajectory is the more useful fact than any single state’s rule. A compliance posture built around today’s eleven-state list is a posture that has already been outdated four times since 2022, and the SB 362 amendment shows the list can grow in depth as easily as it grows in headcount.
What a Growing ISO Should Track
An ISO expanding into a new state inherits whatever that state’s law requires the moment a transaction touches it, not on some later renewal date. Louisiana’s zero-exemption status is the clearest example: a broker used to operating under a five-transaction grace period in every other state on this list gets no such grace period there.
The practical takeaway from the timeline itself is less about memorizing eleven specific dates and more about recognizing the direction the count is moving. A state not yet on this list in 2026 is not guaranteed to stay off it in 2027, given the pace documented above.
The Numbers
Two states had an operative commercial financing disclosure law by the end of 2022: California (effective December 9, 2022) and Virginia (effective July 22, 2022).
Alston Consumer Finance, Commercial Financing Disclosure Requirements & Exemptions
Six states had an operative law by the end of 2023, adding Utah, Connecticut, Florida, and New York; eight states by the end of 2024, adding Georgia and Kansas.
Eleven states had an operative law by the end of 2025, adding Missouri, Texas (September 1, 2025), and Louisiana (August 1, 2025), reported as the first state with no de minimis exemption at all, though the exact date and provider-threshold definition carry some cross-source disagreement not independently resolved here.
Alston Consumer Finance, Commercial Financing Disclosure Requirements & Exemptions
California’s SB 362, effective January 1, 2026, requires APR disclosure on qualifying post-offer communications and restricts “rate”/“interest” language for non-APR pricing.
Cloudsquare, California SB 362: New APR Disclosure Requirements for Brokers and Lenders
Sources
The external data in this article 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.
- Alston Consumer Finance, Commercial Financing Disclosure Requirements & Exemptions
- Venable LLP, State Commercial Financing Disclosure Laws
- Cloudsquare, California SB 362: New APR Disclosure Requirements for Brokers and Lenders