What is the NY LLCTA?
Effective January 1, 2026, the New York LLC Transparency Act requires all LLCs formed outside the United States that are authorized to do business in New York to submit to the New York Department of State either (1) a Beneficial Ownership Information (BOI) report or (2) an attestation of the exemption claimed. The contents and exemptions are similar in scope to the federal CTA, but the NY LLCTA differs in several important ways:
- It only applies to LLCs registered in New York
- Exempt entities must still file (an attestation of exemption)
- Annual updates are required, including for exempt entities
- All BOI filings must include company applicant information
- The window to file after forming or registering an LLC in New York is 30 days
- There is no requirement to provide an image of a government ID
Key filing deadlines
- LLCs formed or authorized on or before January 1, 2026 must file by January 1, 2027.
- LLCs formed or authorized after January 1, 2026 must file within 30 days of filing their articles of organization or application for authority.
- After the initial filing, an annual statement is required that confirms or updates the BOI, or re-attests to an exemption.
Who must file?
- Foreign LLCs (formed elsewhere, authorized in New York) must submit BOI unless exempt.
- Exempt entities must file a formal attestation of exemption under penalty of perjury.
For both exempt and non-exempt entities, the report must be confirmed or updated on an annual basis. Domestic LLCs (formed in New York) and LLCs formed in other U.S. states are not currently subject to this law.
What must be reported?
BOI filings must include the following for each beneficial owner and applicant (where applicable):
- Full legal name
- Date of birth
- Current street address (home or business)
- A unique ID number (e.g., driver's license or passport)
Unlike the federal CTA, New York does not require submitting images of ID documents, and it does not provide for FinCEN identifiers or an equivalent.
Annual reporting obligation
After the initial filing, LLCs—whether reporting or exempt—must submit an annual statement confirming or updating:
- Beneficial ownership details
- Principal office address
- Exemption status (if applicable)
- Any additional information required by the NY Department of State
Penalties for non-compliance
Failure to file can result in:
- Past-due status after 30 days; delinquent status after two years
- Civil penalties of up to $500 per day
- Risk of suspension, dissolution, or revocation of authority to do business in New York
Five steps to get ahead — the SingleFile advantage
- Assess eligibility. Determine whether your LLC must file or can claim an exemption.
- Identify key individuals. Pinpoint your beneficial owners and company applicants.
- Collect BOI data. Securely gather the required personal and government-ID information.
- Implement an annual reporting system. Assign responsibilities and set reminders for the annual statement.
- Leverage expert support. Use SingleFile's compliance platform to collect sensitive information, keep it safe, streamline filings, and stay in control.
How this differs from the federal CTA
The federal Corporate Transparency Act (CTA) requires BOI reporting to FinCEN. Under the current Interim Final Rule (March 2025), only foreign reporting companies must file with FinCEN. The NY LLCTA is a separate, state-level requirement administered by the New York Department of State—so a foreign LLC registered in New York may need to comply with both the federal CTA and the NY LLCTA.
Resources
For the most up-to-date New York LLC beneficial ownership requirements—how to submit, fees, the disclosure report, attestation of exemption, application, and FAQs—visit the New York Department of State at dos.ny.gov/beneficial-owner-disclosure.