Moving From Pulley to Carta: Do You Have to Use Carta for Your Next 409A Valuation?
Author: Redwood Valuation Content Team
Published: September 24, 2026
For Pulley customers taking the Carta migration path, the current 409A valuation is the more straightforward part of the transition. Pulley's shutdown FAQ says Carta can accept your existing Pulley valuation and fair market value as-is if you provide a copy. It also says Carta will support the defense of Pulley's prior 409A valuation work following the transition. The harder question is who performs your next valuation. The short answer is that using Carta for your cap table does not by itself mean Carta has to perform that valuation. Carta's platform can record a valuation from another firm. Pulley's FAQ nevertheless points to Carta as the next provider, and the terms of your new Carta agreement may affect how that choice works in practice.
What Pulley's FAQ Says Happens at Your Next Valuation
The same FAQ answer continues: "Once your 409A expires, Carta's 409A team will act as the provider." Under that description, Carta becomes the provider for your next valuation once your Pulley valuation is treated as expired. Elsewhere, the FAQ presents 409A valuations as one of the services Carta offers alongside the cap table.
The FAQ therefore describes a default path, not necessarily a requirement. It does not explain how Carta will decide that your Pulley valuation has "expired." The regulations do not define a vendor "expiration" date. Instead, a previously calculated value is not reasonable for a later grant if it fails to reflect later information that may materially affect the company's value or if the valuation date is more than 12 months before the date the value is being used. That means your company may need a fresh valuation before the first anniversary. We explain that standard in our article, “Does Pulley's Shutdown Invalidate Your 409A Valuation?”.
Carta's Platform Can Record a 409A Valuation From Another Firm
Carta's help center includes a guide to adding a "non-Carta FMV." A user with the right permissions selects "Non-Carta 409A" as the valuation source, enters the valuation provider, and states the reason for using an outside valuation. That lets the company keep its equity records on Carta while recording a fair market value determined by another provider. Contract terms are a separate issue, addressed below. We cover the broader distinction between the two services in “409A Valuation vs. Cap Table.”
What Carta's 409A Valuation Service Involves
If you use Carta for the next valuation, it helps to know what Carta says about its own service. According to Carta's 409A valuation page, your company needs to be onboarded onto Carta to request a valuation. A dedicated 409A team prepares the fair market value using proprietary software, and analysts are available afterward to answer questions about the result. Carta also describes an automatic Flash 409A workflow for eligible early-stage corporations with 409A in their subscription. If your company is eligible and has not already submitted an update request, it can receive a draft Flash 409A the day after the prior valuation "expires" in Carta's workflow. The new FMV is applied only after your company reviews and accepts it. Whether that workflow applies to your company depends on its Carta subscription and the eligibility criteria.
The 409A page says customers on Carta's Grow and Scale plans receive valuations at no additional cost. It does not list a separate valuation price, so ask how valuations are priced under your new agreement, including after the first year. It is also worth asking who reviews and signs each report and what audit support is included, the same questions you would ask any provider.
What the Transition Terms Leave Open
Carta's platform can record an outside valuation, but that does not tell you whether the contract allows one on the same terms. Pulley's FAQ says migrating customers sign a new agreement with Carta, with current Pulley pricing honored for the first full year and a credit for any unused, prepaid Pulley balance. It does not say whether 409A valuations are bundled into that agreement, whether pricing changes if you use another firm, or what year-two terms look like. For those answers, review the Carta agreement with these valuation questions in mind.
Questions to Ask Before You Sign the Carta Agreement
Are 409A valuations included in the new agreement, and are they optional?
If we use an outside valuation firm, does our pricing change in year one or afterward?
How will Carta determine when it considers our Pulley valuation "expired"?
How will Carta handle later information that may materially affect the company's value?
Who will prepare and sign our future valuations, and what audit support comes with them?
If we record a non-Carta 409A valuation, is there any fee or process requirement on our side?
If a Carta 409A valuation request is already open, how do we record an outside valuation? Carta's help center says that with an active request, a company cannot add a non-Carta FMV itself and must ask Carta's valuation analyst to add it.
When to Make the Valuation Decision
Pulley's FAQ sets November 30, 2026 as the deadline to opt in to Carta's migration offer with the pricing guarantees and collaborative migration support it describes. That deadline governs the migration offer, not when a new 409A is needed. The FAQ also does not tie the deadline to choosing a valuation provider. Your company may need a fresh valuation soon after migration in either of two situations: its existing valuation will be more than 12 months old when it makes planned grants in early 2027, or later information may materially affect its value before those grants. Choosing the provider before then avoids having the default decide for you. For the Pulley-specific situations that call for a new valuation, see article, “When Should a Pulley Customer Get a New 409A Valuation?”.
Using a Separate Valuation Firm Alongside Carta
If you want to use Carta for cap-table administration but a different firm for valuation work, an existing Pulley valuation can support later grants as long as continued reliance on that value remains reasonable under the Section 409A valuation rules. When a fresh valuation is needed, another provider's valuation can be recorded in Carta as a non-Carta 409A, subject to whatever your Carta agreement says.
Redwood specializes in 409A valuations and is separate from any cap-table platform. For pre-seed through Series A companies, Redwood Seed delivers 409A valuations in five business days for $2,500. If you move valuation work from Pulley to Redwood, the package also includes audit support for the prior year's valuation. Talk to Redwood about a 409A valuation for your Carta cap table.