NMLS Annual Renewal for Money Transmitters: The 2026 Checklist

The 2026 NMLS annual renewal window for money transmitter licences opens on 1 November 2026 and closes on 31 December 2026. A licence that is not renewed by 31 December expires, and the company immediately loses its authority to transmit money in that state. Some states allow late reinstatement from 1 January to the end of February 2027 with extra fees; others do not. Regulators renew only licences that are clean in NMLS, so the work starts in October, not in the last week of December.

NMLS, the Nationwide Multistate Licensing System, is the platform state regulators use to issue and supervise money transmitter licences. A money transmitter licensed in 15 states renews 15 licences, each judged by its own regulator. The 2024 NMLS Money Services Businesses Report counted 599 licensed money transmitter companies holding 8,858 money transmitter licences, and the average money transmitter did business in 15 states.

This checklist sets out the timetable, what each regulator looks at, the fees, what happens if the deadline is missed, and the deficiencies that most often stop a renewal.

The 2026 renewal timetable

The renewal and reinstatement dates come from the NMLS renewal guidance. The call report dates follow the 45-day rule in the NMLS MSB Call Report guidance.

What renewal means for a money transmitter

Renewal is an attestation, not a fresh application. In NMLS, the company confirms that its record is current, attests to the accuracy of its filings, and submits a renewal request with fees for each licence. The regulator then decides whether to approve it.

Where a state has adopted the Money Transmission Modernization Act (MTMA), the model money transmission law written by state regulators through the Conference of State Bank Supervisors (CSBS), the licence term runs from 1 January to 31 December. The licensee files a renewal report describing each material change since its original application that it has not already reported. The CSBS reports that 31 states had enacted the MTMA in full or in part as at September 2026.

The practical point: a regulator reviewing a renewal has your full NMLS history in front of it. Any gap between what you reported during the year and what your renewal says will be noticed.

What regulators check before they renew

NMLS publishes a list of items that can prevent renewal eligibility. Each one should be cleared before 1 November.

Two further checks sit outside that list. First, net worth: Nevada, for example, states that a licence will not be renewed if the regulator cannot confirm adequate tangible net worth at the time of renewal. Tangible net worth means assets minus liabilities and intangible assets such as goodwill. Second, the state renewal checklist: each regulator publishes its own renewal requirements and fees, which NMLS collects in the Renewal Checklist Compiler and the Renewal Deadlines, Requirements and Fees Chart.

The 2026 renewal checklist, step by step

1. Pull your licence list. Confirm which licences are in a renewable status and which, if any, you intend to surrender using the Do Not Renew option.
2. Clear licence items and invoices. Work through every open item on the company and any branches.
3. Update the company record. Check addresses, legal and trade names, control persons, executive officers and direct and indirect owners. File amendments now; some need regulator approval.
4. Check each surety bond. Confirm the amount matches the state formula for your current volume. Under the model law, the bond is the greater of USD 100,000 or the average daily money transmission liability in the state over the last three months, capped at USD 500,000.
5. Confirm net worth and permissible investments. Permissible investments are eligible assets, such as cash and specified high-quality securities, that must at least equal outstanding customer obligations at all times.
6. Reconcile your reporting. Make sure the four quarterly MSB Call Reports, the audited financial statements and any state annual reports tell the same story. Our MSB Call Report guide covers this in detail.
7. Run the state renewal checklists. Gather any state-specific documents and confirm which fees are paid inside NMLS and which are paid directly to the state.
8. Attest and pay. Submit the renewal requests and fees well before 31 December, leaving time for regulators to raise questions.
9. Diarise the federal renewal. If your FinCEN registration period covers 2025 and 2026, the Form 107 renewal is due by the same 31 December deadline. See our FinCEN MSB registration page.

Fees

NMLS charges its own processing fee for each renewal on top of state fees. The NMLS annual renewal fees are:

State agencies charge their own renewal fees, late fees and assessments, which vary by state and are listed in each state renewal checklist. Some states collect fees outside NMLS. Professional support for a renewal programme is quoted as a fixed fee set out in a written proposal.

Late renewal, reinstatement and expiry

If a company licence is not renewed by 31 December, NMLS treats it as expired, and the company loses its authority to conduct licensed activity in that state immediately. Expiry can also end related branch licences.

Reinstatement runs from 1 January to the end of February and works like a renewal: the company attests to its record, submits the request and pays all fees, plus any reinstatement fees or penalties. Not all states allow reinstatement. In a state that does not, the only route back is a new application, during which the firm cannot transmit money for customers in that state. Transmitting money in the gap is unlicensed money transmission, which carries state penalties and federal exposure under 18 U.S.C. 1960. Our article on unlicensed money transmission explains how regulators treat that.

Common deficiencies that stop a renewal

The most useful evidence of what regulators look for is in their own orders. On 9 February 2026 the Washington Department of Financial Institutions entered a consent order with CoinZoom, Inc., a licensed money transmitter and currency exchanger. The underlying examination covered April 2022 to December 2024 and alleged, among other things:

• tangible net worth below one third of the USD 3,000,000 requirement in 2022, 2023 and 2024
• a fourth quarter MSB Call Report and draft audited financial statements with conflicting figures
• annual assessment reports that did not reconcile with the four quarterly call reports
• a first quarter 2024 call report due on 15 May 2024 but filed on or about 29 May 2024
• adverse actions in other states not reported within 30 business days
• no evidence that the USD 100,000 surety bond matched transmission volume

The order required CoinZoom to surrender its Washington licence, barred it from the Washington money transmitter industry for three years and imposed a USD 150,000 fine, of which USD 50,000 was stayed. CoinZoom did not admit wrongdoing.

The pattern is familiar: each item is a routine filing. Firms rarely lose a licence over one late report. They lose it when a regulator sees the same weakness in net worth, reporting accuracy and change notifications at once, and concludes the business does not control its own numbers.

Building renewal into the year, not the quarter

The firms that renew without incident treat renewal as the last step of a year-round calendar. They file call reports on time and reconcile them to the audited accounts, report material changes as they happen, resize bonds when volume moves, and keep a single owner for the NMLS record. Renewal then becomes an attestation of facts already on file.

Regulatory Counsel supports licensed money transmitters through ongoing compliance support and regulatory reporting, including renewal readiness reviews across every state on the US money transmitter licence footprint.