Yes. A Pulley 409A stays valid after Pulley shuts down on December 8, 2026. A 409A valuation is an appraisal of your common stock as of a date. It is not tied to the software that ordered it. The safe harbor lasts up to 12 months from the valuation date, or until a material event, whichever comes first.
What changes is access to the file. Download the signed report now: Pulley's services end December 8, 2026, and limited access to Pulley data ends January 31, 2027, per Pulley's shutdown FAQ.
Your 409A expires on its own clock, not Pulley's
The Treasury regulations, at 26 CFR 1.409A-1(b)(5)(iv)(B)(2), presume an independent appraisal reasonable if it is dated no more than 12 months before the grant it is applied to. Two things end that window early:
- Twelve months pass from the valuation date.
- A material event changes the company's value, such as a priced round, an acquisition offer or a large secondary sale.
The vendor closing is neither.
| Your Pulley 409A valuation date | Safe harbor ends, with no material event |
|---|---|
| March 1, 2026 | March 1, 2027 |
| June 15, 2026 | June 15, 2027 |
| November 1, 2025 | November 1, 2026 (already expired) |
Check your own dates with the free 409A expiry checker.
Download four things before January 31, 2027
- The signed valuation report (PDF). This is the document an auditor or the IRS will ask for.
- The valuation date and fair market value per share, exactly as the report states them.
- Any valuation model or supporting exhibits Pulley provided.
- The data room ZIP (Company → Data Room → Download All), which usually holds the report and the board consent that adopted it.
Store them where your company controls them, not only in the new vendor.
Carta accepts it, and so can any other provider
Pulley's FAQ says Carta can accept Pulley's existing 409A and fair market value as-is if you provide a copy, will act as the 409A provider once it expires, and will support the defense of Pulley's prior 409A work after the transition.
If you move somewhere else, the report is still yours. Record it with its original valuation date; do not restart the 12 months from the day you import it. In Capable, the 409A record holds the report, the valuation date and the fair market value, reminds you 30 and 7 days before it expires, and uses the value as the exercise price floor when you draft grants.
Order a new 409A only when one of three things is true
- The 12 months are nearly up and you plan to grant options.
- You closed a priced round, or signed a term sheet you expect to close.
- The business changed materially, such as a large revenue jump, an acquisition offer or a secondary sale at a set price.
Otherwise, keep granting on the Pulley 409A until it expires. When you need a new one, published prices start around $1,000; see what a 409A costs and Capable's $1,499 409A service.
For the full move, see the Pulley migration checklist and what to do before December 8.
This guide is general information, not tax or legal advice.