New York Limited Liability Company Transparency Act In Effect As Of January 1, 2026, But Its Applicability Is Currently Limited

Enacted in late 2023, the New York Limited Liability Company Transparency Act (the “NYS CTA”) goes into effect on January 1, 2026. Modeled on the federal Corporate Transparency Act (the “Federal Act”), the NYS CTA was intended to impose beneficial ownership information (“BOI”) reporting requirements for each limited liability companies (an “LLC”) formed or registered to do business in New York State, unless the LLC is exempt from such requirements. Under the NYS CTA, starting on January 1, 2026, LLCs not exempt from the law will be required to file annual BOI statements or exemption statements with the New York Department of State (“NY DOS”). The NYS CTA imposes significant penalties for noncompliance, and there are specific deadlines and requirements for reporting.