A new statute in New York, entitled the LLC Transparency Act (the NY LLCTA), originally signed into law by Gov. Kathy Hochul on Dec. 23, 2023, was amended on March 1, 2024. As noted in our previous client alert discussing the NY LLCTA (which can be found here), the NY LLCTA was scheduled to go into effect on Dec. 21, 2024. However, the amendment to the law postponed the effective date until Jan. 1, 2026.

Limited liability companies that are formed or authorized to do business in New York prior to Jan. 1, 2026, will now have until Jan. 1, 2027, to file initial beneficial ownership reports with New York’s Department of State (DOS).

Limited liability companies that are formed or authorized to do business in New York after Jan. 1, 2026, will have 30 days from formation or authorization to do business to provide the DOS with the required disclosures.