New York Enacts LLC Transparency Act

Law requires foreign LLCs doing business in NY to disclose beneficial owners

Published on Feb. 10, 2026

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Effective January 1, 2026, the New York LLC Transparency Act (NY LLCTA) requires certain limited liability companies registered to do business in New York to disclose information about their individual beneficial owners. The law applies only to foreign (non-US) LLCs, as the state's definition is currently tied to the narrowed federal Corporate Transparency Act (CTA) passed in 2025.

Why it matters

The NY LLCTA aims to increase transparency around corporate ownership, particularly for foreign entities doing business in the state. This comes as the federal CTA was significantly narrowed in scope, leading New York to implement its own beneficial ownership reporting regime. The new law could impact financial institutions and other companies with foreign LLC structures operating in New York.

The details

Under the NY LLCTA, foreign LLCs authorized to do business in New York must file a beneficial ownership information report with the state Department of State, disclosing details like the full legal names, dates of birth, addresses, and identification numbers of their beneficial owners. Exempt entities like banks and insurance companies must still file an attestation of exemption annually. Companies have compliance deadlines of 30 days for new foreign LLCs and by the end of 2026 for existing ones.

  • The NY LLCTA takes effect on January 1, 2026.
  • New foreign LLCs authorized in NY on or after January 1, 2026 must file within 30 days.
  • Existing foreign LLCs authorized before January 1, 2026 must file by December 31, 2026.

The players

New York LLC Transparency Act (NY LLCTA)

A state law that requires certain limited liability companies registered to do business in New York to disclose information about their individual beneficial owners.

Corporate Transparency Act (CTA)

A federal law that was significantly narrowed in scope in 2025, leading New York to implement its own beneficial ownership reporting regime.

New York Department of State (NYDOS)

The state agency that will receive the beneficial ownership information reports and attestations of exemption under the NY LLCTA.

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What’s next

The New York Department of State is expected to provide additional guidance on the NY LLCTA's enforcement and potential penalties for noncompliance.

The takeaway

The NY LLCTA represents New York's effort to increase transparency around corporate ownership, particularly for foreign entities doing business in the state, in the wake of the federal Corporate Transparency Act's narrowed scope. Companies with foreign LLC structures operating in New York should closely monitor developments and ensure compliance with the new reporting requirements.