Blue Sky Reg D Renewal Requirements
Blue Sky renewals are not universal, and that often creates confusion for issuers. While many states require an initial notice filing for a Reg D offering (filed through Form D), only a limited number impose ongoing renewal or annual sales-reporting requirements. Understanding where renewals apply and where they do not is essential to avoiding unnecessary filings or missed obligations.
Where a renewal is required, it is typically tied to a state-assessed annual notice or sales fee. In those states, the renewal deadline is commonly measured on a fixed cycle, such as a 12-month period from the state’s effectiveness date or receipt of the original notice. States that do not assess an annual notice fee generally do not require a renewal, although amendments may still be required if there are material changes to the offering.
Because renewal obligations vary by jurisdiction, issuers benefit from distinguishing between:
- States that require no renewal after the initial notice
- States that require periodic renewal tied to an annual fee
- States that impose late fees if a renewal is missed
The table below reflects this operating standard by showing, for each state, whether a Form D renewal fee applies and whether a late fee is assessed. Where no renewal or late fee is required, the table indicates “No.” Issuers should always confirm current requirements using authoritative fee references, as state rules and fee schedules may change.
| State | Renewal Fee | Renewal Late Fee |
|---|---|---|
| Alabama | No | No |
| Alaska | $600 | No |
| Arizona | No | No |
| Arkansas | $100–$500 (variable) | No |
| California | No | No |
| Colorado | No | No |
| Connecticut | No | No |
| Delaware | No | No |
| District of Columbia | No | No |
| Florida | No | No |
| Georgia | $100 | No |
| Hawaii | No | No |
| Idaho | No | No |
| Illinois | $100 | No |
| Indiana | No | No |
| Iowa | No | No |
| Kansas | No | No |
| Kentucky | No | No |
| Louisiana | No | No |
| Maine | No | No |
| Maryland | No | No |
| Massachusetts | No | No |
| Michigan | No | No |
| Minnesota | Variable (amendment-based) | Variable |
| Mississippi | $300 | $50 |
| Missouri | No | No |
| Montana | Variable | No |
| Nebraska | No | No |
| Nevada | $500 | No |
| New Hampshire | No | No |
| New Jersey | No | No |
| New Mexico | No | No |
| New York | Yes (every 4 years, $300–$1,200) | $30 |
| North Carolina | No | No |
| North Dakota | $100 | $250 |
| Ohio | No | No |
| Oklahoma | No | No |
| Oregon | No | No |
| Pennsylvania | No | No |
| Puerto Rico | $350–$1,500 | No |
| Rhode Island | No | No |
| South Carolina | $300 | No |
| South Dakota | No | No |
| Tennessee | $100 | No |
| Texas | Variable (up to $500) | No |
| U.S. Virgin Islands | $50 | $50 |
| Utah | No | No |
| Vermont | $820 | No |
| Virginia | No | No |
| Washington | No | No |
| West Virginia | No | No |
| Wisconsin | No | No |
| Wyoming | No | No |
Disclaimer: State requirements are subject to change without notice. The information on this page is provided for general informational purposes only and should not be construed as legal advice. You are responsible for confirming that your filings and activities comply with all applicable laws and regulations. Biasly provides filing assistance but does not provide legal advice.