Who can perform a 409A valuation?

For most startups, the clean answer is: a qualified independent appraiser who regularly values private-company equity. That is the practical route to the independent-appraisal safe harbor.

The regulations do not make one professional designation the universal ticket. What matters is whether the person has the knowledge, experience, education, and training to perform the assignment, and whether the method is reasonably applied to the company's actual facts. Credentials can support that judgment, but letters after a name do not rescue a weak report.

There is a separate safe harbor for certain illiquid startup stock that allows a qualified person to perform the valuation without being independent. It comes with eligibility conditions and requires a written report prepared reasonably and in good faith. Relevant experience generally means at least five years in fields such as business valuation, appraisal, financial accounting, investment banking, private equity, or secured lending.

That internal route exists, but it creates practical friction. The person needs real valuation competence, enough distance to challenge management's preferred answer, and the ability to defend the work later. Your auditor, buyer, and counsel may still prefer an outside report.

When choosing a provider, ask who performs and signs the work, how often they value companies at your stage, what methods they use, and whether support is included if questions arrive later.

Read why independence matters and why doing your own 409A is usually a bad trade. The provider section of the founder's guide gives you the full screening list.