Client Alert: New York LLC Transparency Act Goes Into Effect January 1, 2026

Tomorrow, January 1, 2026, the New York LLC Transparency Act goes into effect, demanding that some LLCs will need to file Beneficial Owner Disclosure Reports. This requires an initial and annual filing detailing who “own[s] and/or control[s] the limited liability company” for the NYS Department of State. According to the department, this new procedure specifically applies to “non-exempt limited liability companies that were formed under the law of a foreign country and which are authorized to do business in New York.”

To find out if your LLC is exempt, visit the list below: https://dos.ny.gov/beneficial-owner-disclosure-exemptions 

Individuals that must be reported are those who possess 25 percent or more of an LLC. The information that must be provided in the report regarding these individuals is the following: 

“(1)  Full legal name;  

(2)  date of birth;  

(3) current home or business street address; and 

(4) a unique identifying number from: (i) an unexpired passport; (ii) an unexpired state driver's license; or (iii) an unexpired identification card or document issued by a state  or  local government  agency or tribal authority for the purpose of identification of that individual” (NYS Department of State). 

For further filing instructions, visit the link below: https://dos.ny.gov/beneficial-ownership-disclosure-filing-instructions 

There is a $25 filing fee, and the form can be submitted through email to dosCorpBOI@dos.ny.gov . There is a credit card authorization form that also must be submitted to address the filing fee.  

Sources:

https://www.cogencyglobal.com/blog/new-yorks-llc-transparency-act-important-updates/?srsltid=AfmBOoqM9AvSr3eRlpjbNMr4t4J0Le-tpZE6cN1E5gGKT4pG1jVSI6Xp 

https://dos.ny.gov/beneficial-owner-disclosure-exemptions 

https://dos.ny.gov/beneficial-ownership-disclosure-filing-instructions 

https://dos.ny.gov/beneficial-owner-disclosure?utm_medium=email&utm_name=&utm_source=govdelivery