The short answer
Under Texas HB 700, providers and brokers of sales-based financing must register with the Office of Consumer Credit Commissioner by 31 December 2026 and renew annually. The law itself took effect in September 2025, but the registration deadline is the part with a date attached — and it applies to brokers, not only funders.
Most of the regulatory coverage in this market is aimed at funders. This one is not. Texas HB 700 names brokers explicitly, and the deadline is four months out.
What HB 700 actually requires
- Providers and brokers of sales-based financing must register with the Texas Office of Consumer Credit Commissioner.
- The deadline is 31 December 2026.
- Registration renews annually thereafter — it is not a one-time filing.
- The underlying law took effect in September 2025; the registration requirement is the piece with the date on it.
The word doing the work there is "brokers". A shop that never funds a deal itself, only places files with funders, is still in scope if it is brokering sales-based financing to Texas merchants.
Where broker registration is now required
Texas is not alone, and this is the shift worth understanding: disclosure obligations have started to come with registration obligations attached, and registration is the one a regulator can check with a database query.
| State | What it involves |
|---|---|
| Texas | OCCC registration, deadline 31 December 2026, annual renewal |
| New York | Broker registration alongside its disclosure regime |
| California | Registration, plus annual provider reporting due 15 March |
| Virginia | Registration alongside disclosure |
| Utah | Registration alongside disclosure |
| Georgia | Registration alongside disclosure |
| Florida | Registration alongside disclosure |
Requirements differ in scope and in who exactly is captured, so the table is a prompt to check rather than an answer. If you place files in any of these states, the question "am I registered there" now has a factual answer that somebody else can look up.
Where the disclosure laws stand
As of August 2026, ten states require commercial financing disclosures: California, Connecticut, Florida, Georgia, Kansas, Missouri, New York, Texas, Utah and Virginia.
California’s SB 362 took effect at the start of 2026 and tightened the rules noticeably for brokers who discuss pricing with merchants directly — which is most brokers.
Why enforcement changed the temperature
Disclosure rules on their own move slowly. What moved the industry was the enforcement that arrived alongside them.
Recent New York Attorney General actions
The through-line in both actions is recharacterisation: courts and regulators treating an advance as a loan, which brings usury caps, licensing requirements and a very different set of consequences into play.
The New York FAIR Business Practices Act
Effective 17 February 2026, New York extended its unfair-and-abusive-practices protections to small businesses and non-profits, not only individual consumers.
In practice that widens what the Attorney General can examine — collection conduct, demand letters, and UCC-1 filing practices among them. For a broker the relevant question is less about your own collections, which you probably do not run, and more about which funders you place files with and how they behave afterwards.
What to actually do about this
- Check whether you broker to Texas merchants. If you do, put the OCCC registration on a calendar before December rather than in December.
- List the states you actually place files in, then check registration status for each one. Most shops have never written that list down.
- Ask your funders how they handle disclosure in the disclosure states, since a merchant receiving an incorrect disclosure is a problem that reaches back to the file you placed.
- Keep your own record of what you told a merchant about pricing. In the states tightening broker conduct, that conversation is increasingly the regulated one.