| Update Applicable to: | Effective date |
| All Limited Liability Companies formed or doing business in New York (unless exempt) | January 1, 2026 |
What happened?
On March 1, 2024, New York Governor Kathy Hochul signed Bill SB 8059, an amendment that adds three new sections to the New York LLC Transparency Act (NYLTA) law and changes other provisions.
What are the details?
Summary:
- The NY LLCTA, modeled after the federal Corporate Transparency Act, will require limited liability companies (LLCs) formed, or qualified to do business, in New York State to report their individual beneficial owner information to the New York Department of State (NYDOS).
- Information reported to the NYDOS will not be accessible to the public.
Changes:
- S.B. 8059 added three new sections to the New York LLC Transparency Act:
- Sec. 1106 (defining relevant terms)
- Sec. 1107 (detailing the new filing requirement)
- Sec. 1108 (violations and penalties)
- The effective date for the NYLTA is January 1, 2026; previously was January 1, 2025.
- Due dates for filings:
- For entities formed/registered before January 1, 2026: the latest reporting date is January 1, 2027.
- For entities formed/registered on or after January 1, 2026: the earliest reporting date will be 30 days January 1, 2026 (previously January 1, 2025).
- For consequences of non-compliance click here.
- For disclosure requirements click here.
- For reporting obligations click here.
Business Considerations
- Review the updated version and plan according to the new dates.
- Update your practices to file on time (if not exempt) the CTA and the NYLTA: you must comply with both, if applicable.
Source References
- New York Enacts LLC Transparency Act Requiring Disclosure of Beneficial Owners (VensureHR)
- New York LLC Transparency Act Update: Finally, Some Clarity (Holland & Knight LLP.)
- Important Updates to the New York LLC Transparency Act (Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.)
- New York State LLC Transparency Act Amendments Signed Into Law (Debevoise & Plimpton LLP)
- New York enacts a revised version of the LLC Transparency Law (Wolters Kluwer N.V.)
- Get Ready for the New York LLC Transparency Act (Perkins Coie LLP)
Resources
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