This article is not legal or tax advice. Pulley is not a law firm. The information here is general guidance only. Consult qualified legal counsel for advice specific to your company's situation.
This guide covers how to submit a 409A valuation request through Pulley, what to expect during review, and how to upload your finalized report so Pulley can apply it to new option grants.
Not sure whether you need a 409A, or when to get one? See Understanding 409A Valuations →
Before you begin
Three things to confirm before submitting your request:
You're on Pulley's Growth Plan. 409A valuations are included on Growth; they're not available on lower tiers. If you're unsure of your plan, check under Company → Billing. 409A valuations are included at no additional cost (2 per subscription year). They are not available as a standalone purchase.
Your cap table is up to date. Pulley's valuation team uses your live cap table as a primary input. Make sure all current securities (options, SAFEs, convertible notes, shares) are recorded before you submit. If you're also planning to issue grants soon after receiving your report, it's worth confirming your equity plan has sufficient capacity first, see Understanding Equity Plan Capacity
You've gathered your required documents. The valuation team needs specific documents to begin. Collecting them before you start the request saves time. See the list below.
Required documents
Have these ready before you begin. Upload everything you have. If a document isn't needed, the valuation team will let you know.
Company documents
Articles of Incorporation, plus any amendments
Business plan or investor deck (any overview of your business model and market is sufficient)
Financial documents
Balance sheet and Profit & Loss statements for the past 2–3 years
If your company is less than 2 years old: financial statements from inception to present
Financial forecast for the next two years (if available; not required as most early-stage companies don't have a formal forecast, and the valuation team will work with what you have)
Cap table documents
SAFEs, convertible notes, and Stock Purchase Agreements
Employee option plan
Employee stock option agreements
Note: Your Pulley cap table will be used directly by the valuation team. Confirm it reflects all current securities before submitting. It is one of the most important inputs in the valuation.
For renewals: Re-upload any documents that have changed since your last valuation (updated financials, new financing documents, amended cap table docs). If you're unsure what's changed, upload everything and the valuation team will confirm what they need.
Request a 409A valuation
Click Compliance & Tax in the left navigation bar
Select the 409A Valuations tab
Click Request New 409A
If you or another administrator has already started a 409A request, the button may read Continue New Request instead. Clicking it will resume the in-progress request rather than starting a new one.
Complete each section of the request form. See the section-by-section guidance below, clicking Next to progress through each section.
Submit your request
Tip: If you're unsure whether a specific document is required, upload it anyway. The valuation team will reach out if they need more context or if anything is missing.
Section 1: General Information
This section establishes the valuation date and designates the primary point of contact for the process.
Valuation Date: The date from which the FMV will be effective. This is typically today's date or the date of a recent triggering event (such as a new hire or funding round). Confirm with your legal counsel if you're unsure.
Point of Contact: The person the valuation team will reach out to if they need additional information or have questions during the process. This should be someone who is responsive and has access to your financial records, typically the CEO, CFO, or whoever manages your cap table. Avoid shared inboxes.
Audit Expectation: Indicate whether you expect to be audited in the next 12 months. If yes, the valuation team will apply additional rigor to the methodology and documentation to support audit defense.
Section 2: Company Overview
This section gives the valuation team the context they need to understand your business and apply the right methodology.
Formation Date: The date your company was formally incorporated.
Business Overview: A 3–4 sentence summary of what your company does, who your customers are, and what stage you're at. A clear, plain-language description is sufficient. You don't need investor-grade language.
Subsidiaries: Indicate whether your company owns any subsidiaries. If yes, the valuation team may request additional documentation.
Business Model: Select the option that best describes how your company generates revenue.
Industry (NAICS Code): Your North American Industry Classification System code. If you don't know it, search the NAICS code lookup using your industry or product description.
Guideline Public Companies: Publicly traded companies the valuation team can use as comparables when modeling your valuation. If you have specific comparable companies in mind, list their ticker symbols here. If you're unsure, leave this blank and the team will identify appropriate comparables.
Timeline to Exit: Your best estimate of when you expect an exit through acquisition or IPO. This informs the valuation methodology.
Most Recent 409A Report: If you've had a previous 409A, confirm whether the report displayed is the most recent one. If not, you'll need to upload the correct report or confirm the details shown.
FMV Direction: Indicate whether management expects the FMV to increase, decrease, or remain flat relative to the most recent report. This contextualises the valuation for the team.
Additional Narrative: Any material context not captured elsewhere. For example: recent pivots, significant customer wins or losses, fundraising in progress, or anything else that may affect the valuation. This field is optional but can meaningfully improve the accuracy of your report.
Document Upload: Upload your board deck, pitch deck, or company overview here. At least one document providing business context is recommended.
Section 3: Capitalization Table
Cap Table Confirmation: Confirm that your Pulley cap table is accurate and up to date. The valuation team uses your live cap table as a primary input, and this is one of the most important data points in the valuation. If there are any errors or missing securities, correct them before proceeding.
Articles of Incorporation (required upload): Upload your most recent Articles of Incorporation, including any amendments. This is a required document. If your AOI has been amended since your last valuation, upload the amended version.
Section 4: Rights and Preferences
Rights and Preferences Confirmation: Confirm that the rights and preferences of your cap table are correct and up to date. This covers liquidation preferences, conversion rights, anti-dilution provisions, and other terms attached to each share class. If you're unsure whether these are accurate, consult your legal counsel before confirming. Errors here can materially affect the valuation output.
Section 5: Financial Information
This is the most data-intensive section. Your accountant should assist with completing the financial fields. All figures should come directly from your company's financial statements.
Copying and pasting values can also result in errors due to decimal alignment or blank spaces, and we recommend manually inputting values to avoid discrepancies.
Balance Sheet
Enter figures as of the balance sheet date shown in the form.
Cash and Cash Equivalents: Total liquid assets such as cash in bank accounts and short-term investments.
Fixed Assets (Net): The value of long-term assets (equipment, property) after depreciation.
Total Assets: All assets combined.
Non-Convertible Debt: Outstanding debt that cannot be converted to equity (e.g. bank loans, lines of credit). Do not include SAFEs or convertible notes here.
Total Liabilities: All liabilities combined.
Total Equity: Total assets minus total liabilities. Compare against the Suggested Total Equity figure shown — if there's a significant discrepancy, verify your inputs before proceeding.
Balance Sheet Upload (required): Upload your most recent balance sheet. This is a required document.
Income Statement / Forecast
Enter Revenue and EBITDA figures across five time periods as shown in the form. The periods are pre-populated based on your valuation date.
Revenue: Total income generated by the business before any deductions.
EBITDA: Earnings Before Interest, Taxes, Depreciation, and Amortisation (a measure of operating profitability). If your company is pre-revenue or has negative EBITDA, enter the actual figures; do not leave the fields blank.
Income Statement Upload (required): Upload your most recent income statement.
Income Forecast Upload (optional): If you have a financial forecast for the next 12–24 months, upload it here. Most early-stage companies don't have a formal forecast. This field is optional and the valuation team will work with what you have.
If you see a warning that the Income Statement/Forecast fields appear incomplete, review each row and confirm all five time periods have been filled in before proceeding. Blank fields will trigger this warning even if some rows are complete.
Section 6: Additional Information
Recent Preferred Round: Indicate whether your company has raised a Preferred round of financing in the last 6 months. If yes, provide the relevant details. A recent priced round is a significant input to the valuation and the team will factor it into the methodology.
What happens after you submit
Once your request is submitted, Pulley's valuation team takes it from there. Here's what to expect:
Step | What happens | Timeframe |
1. Submission received | Pulley's valuation team reviews your documents | Immediately |
2. Follow-up (if needed) | A valuation expert may reach out for additional information | Within 1–2* business days |
3. Draft report delivered | You receive an initial draft of your 409A report by email | Within 3–5* business days of receiving all inputs |
4. Review period | You review the draft and can provide feedback or ask questions | At your pace |
5. Final report approved | You approve the draft in Pulley; the report is locked and finalized | Upon your approval |
* For later-stage companies, the timeline may be slightly longer. Pulley's Valuations team will communicate any delays.
Review and approve your draft report
Watch for an email notification when your draft is ready
Open the draft in your 409A Valuations dashboard under Compliance & Tax
Review the valuation for accuracy. Key things to check:
FMV per share: does it align with your expectations given recent funding activity and company stage?
Valuation date: confirm it matches the date you submitted the request
Methodology: common methods include OPM (Option Pricing Model) and PWERM (Probability-Weighted Expected Return Method); the report should explain which was used and why
If anything looks off, contact the valuation team before approving
If you have questions about the report, contact the valuation team directly at valuations@pulley.com
Once satisfied, click Approve in your Pulley account to finalize the report
Once approved, the report is locked. Pulley will automatically apply the FMV to all new option grants issued from that date forward.
If the FMV seems higher than expected given your company's stage or recent funding activity, you are not locked in. Contact the valuation team at valuations@pulley.com before clicking Approve to discuss the methodology. Once you approve, the report is finalized and cannot be revised.
Upload a 409A report you received outside of Pulley
If you used a third-party valuation firm and want to record the report in Pulley, use this flow instead of the request flow above.
In Pulley, navigate to Compliance & Tax
Select the 409A Valuations section
Click Record FMV
Enter the valuation provider, effective and expiration dates, FMV for common and non-voting common shares
In the Documents section, upload a copy of the report to have on file
Click Save
Important: Once saved, Pulley will use this FMV as the exercise price for all new option grants until a new 409A is uploaded. Verify the report date and FMV per share are correct before saving. An incorrect entry will apply the wrong exercise price to grants issued after that point.
What Pulley does with your 409A report
Once your report is finalized or uploaded, Pulley:
Stores the report securely in your account
Automatically applies the FMV to new option grants issued after the report date
Tracks the 12-month expiration date and alerts you when a renewal is due (via both email and an in-app notification) in your Pulley dashboard
And if your valuation is ever challenged:
Provides free lifetime audit review support for valuations completed through Pulley
Common questions
How long does a 409A valuation take through Pulley?
In most cases, you'll receive a draft report within 3–5 business days of the valuation team receiving all required inputs. If follow-up is needed to gather additional documents or clarify details, that timeline starts from when the complete information is received. For later-stage companies with more complex financials, the process may take a few additional days.
What if I already have a 409A from another firm, can I upload it to Pulley?
Yes. Use the Upload 409A Report flow described above. You'll enter the report date, FMV per share, and expiration date, and upload the PDF. Pulley will apply that FMV to new option grants going forward, just as it would for a report completed through Pulley.
What happens if my 409A expires before I get a new one?
You should not issue new option grants while your 409A is expired. Options issued without a current valuation in place may not meet the requirements of IRC Section 409A, which creates tax risk for employees and legal exposure for the company. If your valuation is close to expiring or has already expired, start the renewal process before issuing any additional grants. Pulley will alert you as the expiration date approaches.
Can I issue options while my 409A request is in progress?
No; an in-progress request does not constitute a valid 409A. You must have an approved report with a finalized FMV before issuing grants. If you need to issue grants urgently, contact the valuation team at valuations@pulley.com to discuss whether expedited processing is possible. Consult legal counsel for guidance on your specific situation.
Does Pulley provide audit defense if my 409A is challenged?
Yes. Valuations completed through Pulley include free lifetime audit review support. If your valuation is challenged by the IRS, Pulley's valuation team will support the defense of the report. This is included in the cost of the valuation, there's no additional charge for audit defense.
When do I need a 409A, and how often?
See When do I need to get a 409A valuation? for a full breakdown of triggering events and renewal timelines.
Do I need a new 409A after raising a SAFE or convertible note?
See Do companies who have raised on a SAFE, KISS or convertible note need a 409A valuation? for guidance on this common scenario.
I have a 409A from another firm, can I record it in Pulley?
Yes. Use the Upload 409A Report flow described above. See also How to record a previous 409A Valuation that occurred outside of Pulley for step-by-step guidance.
How does Pulley conduct its valuations?
See How are 409A valuations done on Pulley? for an overview of the methodology Pulley's valuation team uses.
Getting support
Contact the right team based on your question:
Submission process or account questions (plan eligibility, how to submit, billing): support@pulley.com
Active valuation, draft report, or FMV dispute (questions about your report, methodology, or pushing back before approving): valuations@pulley.com