The New York LLC Transparency Act (Sections 1106, 1107 and 1108, Chapter 34, Section 11, of New York’s Limited Liability Company Law) (Act), has been signed into law and takes effect January 1, 2026. Each non-exempt Limited Liability Company (LLC) formed or qualified to do business in New York will be required to file a beneficial ownership disclosure (BOD) with the New York Department of State (DOS). LLCs that are exempt will still be required to file an attestation of exemption with DOS. The beneficial ownership disclosure will identify the name of each beneficial owner and applicant of the reporting company and include such person’s date of birth, home or business address and an identifying number from a passport or state (or local governmental or tribal authority) issued Driver’s License or ID. The Act uses the same definitions for beneficial owner, applicant and reporting company, as well as exemptions for exempt LLCs, as are in the Federal Corporate Transparency Act.
LLCs formed on or after January 1, 2026 must, within 30 days after formation, either file a BOD with the DOS or, if exempt, file an attestation of exemption with DOS. LLCs formed prior to January 1, 2026 have until 1 year after January 1, 2026 to either file a BOD with the DOS or, if exempt, file an attestation of exemption with DOS.
After the initial filing, each LLC that is a reporting company must file an annual statement with DOS, among other things, updating beneficial ownership disclosure information.
If you have questions or need more information about how the Act affects you or your company, please contact Cuddy & Feder’s Transactional Department.
