November 5, 2025
Client Alert: New York LLC Transparency Act: What New York LLCs Need to Know Before 2026
Background:
The New York Limited Liability Company Transparency Act (“NY LLCTA”), which was modeled after the Corporate Transparency Act (“CTA”), is set to take effect on January 1, 2026. The NY LLCTA, originally signed into law on December 23, 2023, and amended on March 1, 2024, imposes new reporting obligations on certain LLCs. If you own, manage, control, or plan to form a limited liability company either in New York or registered to do business as a foreign LLC in New York, this legislation will create reporting obligations about who owns and controls your company. LLCs formed or registered on or after January 1, 2026, must file a Beneficial Ownership Information (“BOI”) report or attestation of exemption within 30 days of formation or registration. LLCs formed or registered before January 1, 2026, have until January 1, 2027, to submit their initial filing with the New York Department of State (“NYDOS”).
The New York Limited Liability Company Transparency Act (“NY LLCTA”), which was modeled after the Corporate Transparency Act (“CTA”), is set to take effect on January 1, 2026. The NY LLCTA, originally signed into law on December 23, 2023, and amended on March 1, 2024, imposes new reporting obligations on certain LLCs. If you own, manage, control, or plan to form a limited liability company either in New York or registered to do business as a foreign LLC in New York, this legislation will create reporting obligations about who owns and controls your company. LLCs formed or registered on or after January 1, 2026, must file a Beneficial Ownership Information (“BOI”) report or attestation of exemption within 30 days of formation or registration. LLCs formed or registered before January 1, 2026, have until January 1, 2027, to submit their initial filing with the New York Department of State (“NYDOS”).