Jan 26, 2026

SOS Registration for Money Transmitter Licenses: Timelines

If you’re planning a multi-state MTL rollout, SOS registration processing times can make or break your launch timeline. Before you can apply for a money transmitter license in any state, you must first register your company with that state's Secretary of State.

Last updated: 
January 26, 2026
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Hero image showing a fintech founder or operations lead mapping out a multi-state money transmitter license roadmap on a laptop, with a U.S. map, state filing icons, and a visible dependency chain labeled “SoS registration → MTL application → license approval → launch” to emphasize timing, processing times, and costs across all 50 states

It sounds like a formality, but SoS registration has real implications for your MTL timeline. Some states process registrations in a day. Others take 30-45 days. If you haven't factored registration into your licensing roadmap, you could be looking at unexpected delays before you even submit your first MTL application.

This guide covers what fintech teams need to know about SoS registration as a prerequisite to money transmitter licensing: costs, processing times, and how to sequence your filings for the fastest path to market.

Why SoS Registration Matters for MTL Applications

Every state requires you to be authorized to conduct business before you can apply for regulatory licenses. This authorization comes through "foreign qualification;" registering with the Secretary of State in each state where you weren't originally formed.

For MTL applicants, this creates a dependency chain:

SoS Registration → MTL Application → License Approval → Launch

You can't start the MTL clock until SoS registration is complete. In slow-processing states, this can add weeks or even months to your timeline.

Related: Build your full SOS foundation with our guide to Secretary of State registration for fintech companies.

What Happens If You Skip This Step

Submitting an MTL application without valid SoS registration will result in:

  • Application rejection or delays while you complete registration
  • Potential resubmission fees
  • Lost time in an already lengthy approval process

Some states will let you submit your MTL application while SoS registration is pending, but you won't receive license approval until registration is complete. Others require proof of registration before they'll accept your application at all.

Planning Your Timeline: Registration Processing by State

When mapping your MTL rollout, start with SoS processing times. These determine how early you need to file before submitting license applications.

Many of the slower states offer expedited options or faster processing timelines depending on submission type (e.g. mail vs. online vs. in-person).  For example, California has a number of expedited services available for a variety of business formation types.

While expedited services are available in many of these states, it can become quite costly!

Fast-Track States (1-2 Days)

These states won't slow you down. You can register and submit MTL applications almost simultaneously.

State Processing Time Annual Fee Due Date
Alaska 1 day $200 January 2nd (biennial)
Colorado 1 day $110 Anniversary month
Indiana 1 day $132 Anniversary month (biennial)
Iowa 1 day $145 April 1st (odd years)
Kentucky 1 day $115 June 30th
Massachusetts 1 day $620 Anniversary date
Mississippi 1 day $100 April 15th
Nevada 1 day $450 End of anniversary month
New Jersey 1 day $175 End of anniversary month
Oregon 1 day $200 Anniversary date
Puerto Rico 1 day $250 April 15th
South Dakota 1 day $150 First day of anniversary month
Wisconsin 1 day $125 Varies by formation date
Alabama 2 days $100 minimum 2.5 months after taxable year begins
Louisiana 2 days $130 Anniversary date
Minnesota 2 days $100 December 31st
Oklahoma 2 days $125 Anniversary date
South Carolina 2 days None* No requirement (unless S/C corp)
Texas 2 days None* No FTR if revenue under $1.18M
Washington 2 days $160 Last day of anniversary month

Moderate Processing (3-15 Days)

Build 1-2 weeks of buffer into your timeline for these states.

State Processing Time Annual Fee Due Date
Connecticut 3 days $180 Anniversary date
Vermont 3 days $135 2.5 months after fiscal year end
Rhode Island 5 days $152.50 September 1st – November 1st
Tennessee 5 days $300 1st of 4th month after fiscal year end
Pennsylvania 2-5 days $70 Every 10 years
Arkansas 7 days $250 May 1st
Kansas 7 days $150 15th of 4th month after fiscal year end
New York 7 days $109 End of anniversary month (biennial)
Montana 1-7 days $120 April 15th
Delaware 1-7 days $400 June 1st (franchise tax)
Ohio 3-7 days $125 July 1st (odd years)
Florida 2-10 days $238.75 January 1st – May 1st
Maryland 10 days $300 April 15th
Nebraska 10 days $110 April 1st (odd years)
West Virginia 1-10 days $126 July 1st
Hawaii 3-10 days $112.50 End of anniversary quarter
Georgia 2-12 days $150 January 1st – April 1st
North Carolina 2-12 days $302 April 15th
Michigan 1-14 days $125 February 15th
Utah 2-14 days $120 Anniversary date
New Hampshire 15 days $200 April 1st
Wyoming 15 days $162 First day of anniversary month
Idaho 1-15 days $100 End of anniversary month
DC 1-15 days $400 April 1st (biennial)

Slow States: Plan Ahead (15-45 Days)

These states require advance planning. File SoS registration 4-6 weeks before you intend to submit MTL applications.

State Processing Time Annual Fee Due Date
Arizona 8-20 days $103 January 1st – April 30th
Virginia 3-28 days $150 End of anniversary month
California 2-30 days $120 Last day of anniversary month
New Mexico 30 days None No annual report required
North Dakota 30 days $150 November 15th
Maine 5-30 days $185 June 1st
Illinois 2-45 days $175 Before 1st of anniversary month

Cost Impact: SoS Fees as Part of Your MTL Budget

SoS registration is a cost component of your overall licensing investment. Here's how it fits into your MTL budget.

Registration Costs Across All States

Category Estimated Cost
Initial Registration Fees ~$8,000-$10,000
Year 1 Annual Reports ~$8,500-$9,500
Registered Agent Fees ~$5,000-$10,000
Total Year 1 SoS Costs ~$21,500-$29,500

How This Fits Into Total MTL Costs

Component Year 1 Cost
MTL Application Fees ~$115,000
Surety Bonds ~$120,000-$140,000
SoS Registration & Compliance ~$21,500-$29,500
Total Year 1 Investment ~$256,500-$284,500

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.

Ongoing SoS Costs (Year 2+)

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.

FAQs

Do I need a registered agent in every state?

Yes. Every state requires a registered agent—an individual or service authorized to receive legal documents on your behalf. National registered agent services can handle all 50 states for $5,000-$10,000 annually.

How much does SoS registration cost across all 50 states?

Initial registration runs approximately $8,000-$10,000. Including first-year annual reports and registered agent fees, budget $21,500-$29,500 for year one.

Can I expedite SoS registration?

Most states offer expedited processing for additional fees. This can reduce processing times significantly but adds to your costs.

Which states have the slowest registration processing?

Illinois (up to 45 days), California (up to 30 days), New Mexico (30 days), North Dakota (30 days), and Maine (up to 30 days) have the longest standard processing times.

Do I need to register with the Secretary of State before applying for an MTL?

Yes. Every state requires valid business registration before accepting license applications. Some states allow concurrent processing; others require completed registration first.

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