The SoS component represents roughly 8-10% of your total year-one licensing investment. It's often overlooked in initial budgeting but adds up across 50 states.
| Category |
Estimated Annual Cost |
| Annual Reports & Franchise Fees |
~$8,500-$9,500 |
| Registered Agent Fees |
~$5,000-$10,000 |
| Total Annual SoS Costs |
~$13,500-$19,500 |
These costs continue every year you maintain your licenses. Factor them into your MTL maintenance budget alongside license renewal fees, surety bonds, and compliance staffing.
Strategic Sequencing: Optimizing Your MTL Rollout
Smart fintech teams sequence their SoS registrations strategically to avoid bottlenecks.
Approach 1: Register Everywhere First
File SoS registrations in all 50 states before beginning any MTL applications. This front-loads the timeline but ensures you're never waiting on registration when you're ready to submit a license application.
Pros: No registration delays during licensing process Cons: Higher upfront costs; paying annual fees in states where you may not apply for months
Approach 2: Prioritized Waves
Register in priority states first, aligned with your MTL application sequence. Most fintechs prioritize based on:
- Market size (California, Texas, Florida, New York)
- Strategic importance (headquarters state, key customer locations)
- Approval speed (states with faster MTL processing)
Pros: Spreads costs over time; aligns spend with licensing progress Cons: Requires careful coordination; risk of delays if registration lapses
Approach 3: Slow States First
Identify states with the longest SoS processing times and file those registrations immediately—even if they're not your first MTL targets. This prevents slow registration from becoming a bottleneck later.
Priority filings for this approach: Illinois (45 days), California (30 days), New Mexico (30 days), North Dakota (30 days), Maine (30 days), Virginia (28 days), Arizona (20 days)
Related -> How Much do MTLs Cost?
Maintaining Good Standing: Why It Matters for Licensed Fintechs
Once you're licensed, maintaining SoS good standing isn't optional. State regulators can revoke or suspend your MTL if your business registration lapses.
What Puts Good Standing at Risk
- Missing annual report deadlines
- Failing to pay franchise taxes (Delaware, Texas, Tennessee)
- Letting registered agent service lapse
- Not updating address or officer information
Consequences of Losing Good Standing
- MTL suspension or revocation proceedings
- Inability to renew licenses
- Contract enforcement issues
- Banking relationship complications
- Reinstatement fees and penalties ($500-$2,000+ per state)
Managing 50 Different Deadlines
With annual reports due throughout the year on different schedules, tracking compliance across all states is operationally demanding.
Fixed calendar deadlines to watch:
- January 2nd: Alaska
- February 15th: Michigan
- April 1st: DC, Iowa, Nebraska, New Hampshire
- April 15th: Maryland, Mississippi, Montana, North Carolina, Puerto Rico
- May 1st: Arkansas
- June 1st: Delaware, Maine
- June 30th: Kentucky
- July 1st: Ohio, West Virginia
- November 15th: North Dakota
- December 31st: Minnesota
Most other states use anniversary-based or fiscal year-based deadlines, requiring tracking specific to your company's registration date.
Special Considerations for Fintech Companies
States With No Annual Report Requirement
Three states don't require annual reports for most entity types:
- Missouri: No annual report required
- New Mexico: No annual report required
- South Carolina: No requirement unless taxed as S or C corp
Texas has no franchise tax for businesses under $1.18M in revenue—but most fintechs exceed this threshold quickly.
Lowest Ongoing Costs
- Pennsylvania: $70 every 10 years (decennial filing)
- Minnesota: $100 annually
- Mississippi: $100 annually
- Idaho: $100 annually
Highest Ongoing Costs
- Massachusetts: $620 annually
- Nevada: $450 annually
- Delaware: $400 franchise tax
- DC: $400 biennially
- Tennessee: $300 annually
Montana: The Exception
Montana is the only state without a money transmitter licensing statute (exemption for intra‑state activity), but interstate operations still require MTLs from other states. SOS registration($120 annually) is still needed if doing business there.
Build SoS Registration Into Your MTL Strategy
Secretary of State registration is a foundational step that's easy to overlook—until it delays your licensing timeline. Smart fintech teams treat registration as the first phase of their MTL rollout, not an afterthought.
Factor registration processing times into your go-to-market plan, budget for ongoing compliance costs, and build systems to track 50 different deadlines. The companies that launch fastest are the ones that sequence every step intentionally.
Ready to streamline your multi-state licensing? Contact Brico to learn how we can help you manage SoS registration, MTL applications, and ongoing compliance in one integrated platform.
Disclaimer: This article is for informational purposes only and does not constitute legal, financial, or regulatory advice. Brico is not a law firm and does not provide legal counsel. Licensing requirements vary by state and depend on your specific business model and circumstances. You should consult with qualified legal counsel before making any licensing decisions or taking action based on this content.