New York LLC Transparency Act

While beneficial ownership information reporting under the federal Corporate Transparency Act (CTA) has essentially been eliminated for US companies and US persons under FinCEN’s interim final rule (IFR) issued on March 21, 2025, New York limited liability companies (New York LLCs) should stay apprised on beneficial ownership information reporting requirements under the New York LLC Transparency Act (NYLTA) which goes into effect on January 1, 2026.

Under the NYLTA, domestic LLCs formed in New York and foreign LLCs registered to do business in New York are required to report beneficial ownership information to the New York State Department of State (NYS DOS).

Unlike the CTA, the NYLTA applies only to New York limited liability companies. In addition, beneficial ownership information reports under the NYLTA must be filed/updated annually or for those LLCs subject to an exemption, an attestation of exemption must be filed annually.

New York LLCs should continue to monitor for further guidance from the NYS DOS as the NYLTA effective date approaches.