New York LLC Transparency Act: Key Requirements and Deadlines

Limited liability companies (LLCs) that conduct business in New York from out of state and those that are based there will face new compliance obligations beginning in 2026 as the New York LLC Transparency Act takes effect. The law requires many LLCs to disclose beneficial ownership information to the state. These rules arrive just as federal beneficial ownership reporting has changed, known as the Corporate Transparency Act (CTA), creating uncertainty for many LLC owners who want to remain compliant.

If you operate an LLC in New York or plan to form one soon, now is the ideal time to understand the requirements, deadlines, and reporting process. This guide outlines the purpose of the Act, what information LLCs must disclose, when reports are due, and how to stay ahead of yearly filings.

1-800Accountant, America's leading virtual accounting firm, supports small business owners in every state, including New York, with affordable, tax-deductible proactive accounting, organized bookkeeping, and year-round advisory, so compliance feels simple and stress-free.

Key Highlights

• New York’s LLC Transparency Act becomes effective January 1, 2026

• This Act applies to LLCs formed in New York and foreign LLCs (out of state) authorized to do business in the state

• LLCs formed on or after January 1, 2026, must file beneficial ownership disclosures within 30 days of formation

• LLCs formed before January 1, 2026, must file by January 1, 2027

• Annual reporting is required under the New York law

• Federal CTA reporting no longer applies to domestic LLCs

• Accurate recordkeeping and consistent bookkeeping will support timely NY LLC annual reporting compliance

What Is the New York LLC Transparency Act?

New York’s LLC Transparency Act introduces a state-specific beneficial ownership reporting process that begins in 2026. While the federal CTA has been scaled back for domestic entities, New York has moved forward with its own set of requirements.

Purpose of the law

The law aims to:

• Prevent fraud.

• Improve transparency.

• Align with broader national trends. 

It focuses on gathering information about individuals who truly control or influence an LLC. This requirement applies only to LLCs. Legal entities, including corporations, sole proprietorships, and general partnerships, are not covered under the Act.

Which LLCs must comply

The Act applies to:

• LLCs formed in New York

• Foreign LLCs authorized to do business in New York

If you’re preparing to form an LLC in New York, it's critically important to understand the new rules and filing obligations before you begin.

What “beneficial owner” means

A beneficial owner is any individual who:

• Exercises substantial control over the LLC, or

• Owns or controls at least 25% of the LLC’s ownership interests

For most small business LLCs, beneficial owners are the members listed in the operating agreement. However, individuals with decision-making authority may also qualify under this new Act.

Filing Requirements for NY LLCs

What must be disclosed

Each LLC reporting company must provide New York state with beneficial owner information, including:

• Full legal name

• Residential address

• Date of birth

• Identifying document information (driver’s license or passport)

• LLC identifying details

Domestic or foreign LLC business owners will need to collect and maintain accurate records for each beneficial owner.

How filings will be submitted

New York is still finalizing its reporting system, but filings will be made with the New York Department of State. An online submission portal is expected to be made available as of or before the Act takes effect.

Accurate bookkeeping and well-organized records make these filings easier and help prevent errors throughout the year.

Penalties for non-compliance

New York small business compliance failures may result in administrative penalties or loss of good standing. Losing good standing can affect the business’s ability to:

• Operate

• Secure financing

• Maintain licenses

Key Deadlines Under the NY LLC Transparency Act

While certain aspects of this Act are being finalized, official updates and legal analyses confirm the following deadlines.

LLCs formed on or after January 1, 2026

LLCs created or authorized in New York on or after January 1, 2026, must file their NY LLC beneficial ownership reporting disclosure within 30 days of formation.

LLCs formed before January 1, 2026

Existing LLCs must submit their initial report disclosure by January 1, 2027. 

Ongoing annual reporting

Unlike the federal approach, New York requires annual reporting. This emphasizes the importance of maintaining accurate financial documentation and organized ownership records. Many business owners rely on affordable full-service small business bookkeeping to keep up with year-to-year compliance tasks.

How New York’s Act Differs From the Federal Corporate Transparency Act

Federal CTA obligations removed for domestic LLCs

In March 2025, FinCEN issued an interim rule stating that domestic LLCs, corporations, and other U.S. entities are no longer required to file federal beneficial ownership reports.

This eliminated the earlier federal deadlines for most small businesses.

New York requirements exist separately

New York’s reporting obligations are entirely separate from the CTA. Even though federal requirements were lifted, New York maintains:

• Its own reporting framework

• Its own deadlines

• An annual update requirement

This means all New York LLCs should prepare for state-level reporting regardless of federal changes. This state-level reporting appears to be more onerous for LLC owners than the federal version would have been.

What NY LLC Owners Should Do Now

Preparing early will make compliance smoother and help prevent penalties and distractions.

Start gathering beneficial ownership information

Begin collecting the required details for every beneficial owner as soon as possible. Gather and securely store:

• Legal names

• Personal addresses

• Identification documents

• Ownership percentages

• Records of management or control roles

Review this information annually to ensure accuracy. Being proactive reduces the risk of missing information when it is time to file.

Incorporate reporting into annual compliance routines

Because New York requires yearly reports, integrate this task into your annual compliance calendar.

Reliable bookkeeping systems and services can streamline ownership and financial documentation. Many owners use tax-deductible full-service small business bookkeeping to stay current throughout the year.

Update operating agreements and internal records

Your operating agreement should clearly outline the ownership structure and control rights. If it is outdated, revise it before the state’s reporting deadlines.

Clear records will help prevent discrepancies during filing.

How 1-800Accountant Helps NY LLCs Stay Compliant

1-800Accountant gives New York-based owners and entrepreneurs peace of mind with expert, year-round support built for small businesses.

Year-round advisory and compliance guidance

With year-round tax advisory, you can stay informed about changing regulations and receive guidance tailored to your LLC.

Full-service bookkeeping that supports accurate reporting

Accurate filings depend on organized financial and ownership records. Our bookkeeping services help keep everything:

• Aligned

• Up to date

• Ready for reporting

Support for new LLC formation and setup

If you’re starting a new business, our LLC formation services provide clear steps and support to ensure you understand your reporting obligations from day one.

Moving Forward

The New York LLC Transparency Act introduces new responsibilities, but with early preparation and strong financial systems, compliance can be straightforward and efficient. Understanding the deadlines and NY LLC disclosure requirements now helps protect your business and maintain good standing.

1-800Accountant is here to support you every step of the way with compliance guidance, bookkeeping, and tax expertise that keeps your business running smoothly. 

Schedule a free consultation today to learn how we can help you prepare your New York LLC for the new reporting requirements.