Listing AutomatEr Start free

Arizona rules for licensed agents

What can an unlicensed assistant do for an Arizona agent?

Arizona’s Department of Real Estate publishes an advisory list. Under the direct supervision and employment of a licensee, an unlicensed assistant may run personal errands, do clerical and administrative tasks and collect in person rent as part of clerical duties, and shall not originate documents, give advice, pricing or opinions of value to a consumer, negotiate on a property or transaction, or assist or direct in procuring prospects. The statement is advisory only.

Rule text read from the 2026 Law Book of the Arizona Department of Real Estate, azre.gov, read November 1, 2026. The assistants statement was read at azre.gov the same day. Informational, not legal advice.

The Department’s list

The list is Substantive Policy Statement No. 2025.02, Unlicensed Assistants, revised February 14, 2025, published by the Arizona Department of Real Estate. It says of itself:

“This substantive policy statement is advisory only.”

What an assistant may do:

“Under the direct supervision and employment of an Arizona licensee, perform the following tasks, which include, but are not limited to:”
“Personal errands for the licensee.”
“Clerical/administrative tasks including filing, copying, mailing, scanning, answering phones, forwarding calls or transcribing callers’ information for licensee”

The third task on its list is collecting in person rent and related fees for the broker or salesperson as part of the assistant’s clerical duties, with a receipt. What an assistant shall not do:

The statement also puts the policy duty on the broker and limits the trust account:

“The employing broker is responsible to have written policies and procedures in place to ensure that unlicensed assistants are not performing any acts that require a license or being advertised in a manner that indicates that the person is licensed.”
“An unlicensed assistant is otherwise not permitted to withdraw monies from the broker’s trust account.”

The list says its tasks “include, but are not limited to” the ones named, so it is not closed. Whether a given task falls on one side or the other is a question for your designated broker.

The licensing statute

The statute is A.R.S. 32-2122, License required of brokers and salespersons. Subsection B:

“It is unlawful for any person, corporation, partnership or limited liability company to engage in any business, occupation or activity listed in subsection A of this section without first obtaining a license as prescribed in this chapter and otherwise complying with this chapter.”

Subsection D reaches acts in a transaction, big or small:

“whether the act is an incidental part of a transaction or the entire transaction”

The test in that subsection is an act, done for compensation or in the expectation of it, that is part of the definition of a real estate broker. The same subsection lets a person who is not a licensee collect in person rent and related fees as part of clerical duties for a licensee, with a receipt.

The unlawful activity rule

The rule is R4-28-306, Unlawful License Activity. Besides acting without a license, it counts as unlawful:

“A broker’s employment of a person as a salesperson or broker if the person does not hold an active license issued to the person under that employing broker”

When it happens, subsection B has the person send the Department an explanation and signed statements, and has the designated broker send a statement of all the unlawful activity. Subsection C softens the result for a short first lapse:

“A person who has no prior history of engaging in unlawful license activity under this Section, who conducted unlawful license activity for not more than 30 days and against whom there are no pending complaints may apply to renew the person’s license or for license change to active status.”

The Commissioner may take disciplinary action under A.R.S. 32-2153 in the other cases, as subsection D has it:

“against a person who engages in unlawful license activity under this Section for longer than 30 days, has previously conducted unlawful license activity, or is the subject of a pending complaint.”

The penalty statute

“A person who acts as a broker or salesperson within the meaning of this chapter, or who advertises in a manner that indicates that the person is licensed as a broker or salesperson, without being licensed as prescribed by this chapter is guilty of a class 6 felony.”

That is A.R.S. 32-2165(A), which also lists exceptions in subsection C, among them a licensee within a year of expiry whose failure to renew was unintentional.

What this page does not settle

The policy statement is advisory and says its list is not limited to what it names. The Law Book’s supervision rule, R4-28-1103, lists the use of unlicensed assistants among the things a broker’s written policies are to manage; see broker supervision in Arizona. The statement’s line on procuring prospects uses the same wording as the definition of a real estate broker quoted on the Arizona referral fee page. Ask your designated broker where a task falls.

Common questions

What can an unlicensed assistant do for an Arizona agent?

The Department’s advisory statement says that under the direct supervision and employment of an Arizona licensee an assistant may run personal errands, do clerical and administrative tasks such as filing, copying, mailing, scanning and answering phones, and collect in person rent and related fees as part of clerical duties, with a receipt. It says its tasks include, but are not limited to, those named.

What can an unlicensed assistant not do in Arizona?

The advisory statement says an assistant shall not originate documents, provide advice, pricing or opinions of value to a consumer, provide advice or negotiate with anyone regarding a property or transaction, or assist or direct in the procuring of prospects, unless exempt.

Who is responsible for an unlicensed assistant in Arizona?

The statement says the employing broker is responsible for written policies and procedures that ensure assistants are not performing acts that require a license or being advertised as licensed.

Is it unlawful in Arizona to do a broker’s work without a license?

The statute makes it unlawful to engage in the activity of a real estate broker or salesperson without first obtaining a license, and it reaches acts done in consideration or expectation of compensation whether incidental to a transaction or the entire transaction.

What happens if someone acts without a license for a short time in Arizona?

The unlawful activity rule says a person with no prior history, no more than 30 days of unlawful activity and no pending complaints may apply to renew or change to active, and the Department issues an Advisory Letter of Concern. Longer, repeated or complained of activity can bring discipline.

Does Listing AutomatEr replace a license?

No. Licensed work stays with you and your broker. The app builds and schedules posts for listings you have permission to market.

Where Listing AutomatEr fits

Listing AutomatEr is a desktop app for Mac and Windows that posts the listings you have permission to market to Facebook Marketplace on a schedule. By default it puts your name on the post as the agent marketing the home and credits the brokerage that holds the listing.

It does not obtain the permission for you, and it does not decide whether a post meets a rule. That stays with you and your broker.

Start the free trial

Current price and trial length are on the pricing page. Cancel anytime.

Sources

This is not legal advice. This page quotes a policy statement, a statute and a rule so you can read them yourself. It is not a lawyer's opinion about your situation. The official text, your brokerage and your own lawyer are the authorities, and the official text wins over this page.