When Should a Pulley Customer Get a New 409A Valuation?
Author: Redwood Valuation Content Team
Published: September 24, 2026
The Pulley shutdown does not, on its own, call for a new 409A valuation. A current valuation can generally continue to support new grants if it is no more than 12 months old on the grant date and still reflects any information that may materially affect value. Moving the cap table to another platform does not change those rules. The shutdown matters because it can bring the need for a new valuation forward or make an existing valuation harder to rely on. If your company has option grants planned for late 2026 or early 2027, these are the situations to check.
The General Triggers Still Apply
The usual 409A refresh triggers do not change because Pulley is closing. Financings, secondary sales, significant changes in performance, and an approaching IPO or acquisition can all make a valuation stale. Our 409A valuation refresh schedule guide walks through those events in detail, and “Does Pulley's Shutdown Invalidate Your 409A Valuation?” explains why the shutdown itself does not invalidate a valuation. The rest of this article looks at how those ordinary rules play out during the Pulley transition.
Four Situations to Check During the Pulley Transition
1. You cannot produce the valuation report or supporting materials
The Pulley-specific risk here is documentation, not automatic invalidation of the valuation. Pulley says the app and customer support will end on December 8. Data will remain available in a limited format through January 31, 2027. If you did not save the final report and key supporting inputs, you may have difficulty substantiating how the value was determined. If those valuation records cannot be recovered, a new valuation is often the more practical path before your next grant. Our Pulley shutdown checklist lists what to save now.
2. Your next grant falls outside the valuation's 12-month window
Count the 12-month period from the valuation date to the planned grant date, not to today. A Pulley valuation dated in early 2026 may no longer support grants made in early 2027.
3. Something material has happened, and a new provider will handle your next valuation
If your company has had a financing, a secondary, or another significant development since the Pulley valuation date, that development can make the existing valuation stale. Because Pulley is shutting down, a new provider will handle the next valuation: Carta's 409A team if you complete the transition to Carta, or another firm you choose. The new provider will typically prepare its own analysis rather than update the Pulley valuation, so allow time to gather the financials, cap table, and prior reports it will request.
4. You are moving to Carta and your valuation is close to expiring
If you complete the Carta migration, Pulley's FAQ says Carta can accept your existing 409A valuation. It also says that once the valuation expires, "Carta's 409A team will act as the provider." The provider change is part of the Carta transition; expiration alone does not make Carta your 409A provider. If you would rather use a different valuation firm, decide that before your next valuation is due. We cover that choice in “Moving From Pulley to Carta: Do You Have to Use Carta for Your Next 409A Valuation?”
When the Shutdown Is Not a Reason to Revalue
If your valuation will be no more than 12 months old at your next grant, nothing material has happened since its valuation date, and you have the supporting records, focus on preserving those records and choosing your next provider rather than ordering a new valuation solely because Pulley is closing.
Sequencing the Work Around November 30 and December 8
If your company does need a new valuation, the order matters. Save the valuation records while full access to Pulley remains. Decide your cap-table path, including whether to opt in to Carta's migration offer by November 30. Choose the firm that will perform the next valuation. Then make sure the valuation supports fair market value on the option's grant date. Under the 409A stock-option rules, the grant date is when the company completes the corporate action that creates the legally binding option. The exercise price is tested against fair market value on that date. The valuation and grant-approval timing therefore need to line up. Getting that timing right up front is much easier than trying to correct a stale-value grant afterward.
Getting Your Next 409A Valuation Scheduled
Redwood is an independent valuation firm specializing in 409A valuations. If you are working out when your next valuation is due or how to transition from Pulley, we can review your current Pulley valuation and help plan the next one. If you move your valuation work from Pulley to Redwood, the package also includes support for responding to audit questions about the prior year's Pulley valuation. Earlier-stage companies can use Redwood Seed, which covers pre-seed through Series A.