New York is preparing to roll out its own version of beneficial ownership reporting—and it arrives sooner than many businesses realize. Beginning January 1, 2026, the New York LLC Transparency Act (LLCTA) will impose new filing obligations on all New York LLCs and foreign LLCs authorized to do business in the state.
While the LLCTA mirrors several elements of the federal Corporate Transparency Act (CTA), it also introduces key differences and broader disclosure requirements, making early preparation essential for business owners and advisors.
New Obligations for NY LLCs Under the 2026 LLC Transparency Act
Just when you thought you were safe from the FinCEN Corporate Transparency Act (CTA) reporting requirements, here comes New York’s version, applicable to New York LLCs and foreign LLCs authorized to do business in New York.
Under the Act, all New York LLCs and all foreign LLCs that are registered to do business in New York are considered to be a “reporting company.” Every reporting company must file either a beneficial ownership information (BOI) disclosure report or an attestation of exemption with the New York Department of State (DOS) on a form to be adopted by the DOS. LLCs existing or registered to do business before January 1, 2026 have until January 1, 2027 to file either the BOI report or the attestation. LLCs formed or registered to do business in New York on or after January 1, 2026 have 30 days from the date of formation or registration as a foreign LLC to complete the filing. Note that New York has not yet provided any forms or created the database to be used as of the date of this writing (November 14, 2025).
For nonexempt reporting companies, the BOI disclosure must identify each of its applicants and “beneficial owners” and report such individuals’ full legal name, date of birth, current home or business street address, and a unique identifying number from a valid government-issued identification document. You may not use the FinCEN Identifier that you might have already obtained. The LLCTA relies on many of the original definitions contained in the CTA, such as the definition of “beneficial owner.” Very importantly, while the CTA exempted Applicants of reporting companies that existed before the effective date of the CTA, New York’s LLCTA does not. No matter when your LLC was formed, your Applicant must be identified.
As with the CTA, certain types of LLCs are exempt from filing. The New York database will not be available to the public and will generally only be used by government authorities for law enforcement and regulatory purposes.
Penalties for noncompliance are up to $500 per day in fines; a mark of “Past Due” in public records if non-compliant for at least 30 days; a mark of “delinquent” in public records if non-compliant for at least 2 years; and potential suspension, cancellation or dissolution for ongoing delinquency.
As New York finalizes its rules and forms, LLCs should begin preparing now to ensure timely compliance. If you need guidance on determining beneficial owners, evaluating exemptions, or planning for the new filing deadlines, the attorneys at Scarinci Hollenbeck can assist.
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