The U.S. Department of the Treasury decided in March to suspend enforcement of the federal Corporate Transparency Act (CTA), but limited liability companies (LLCs) formed or authorized to do business in New York state still face state disclosure requirements.
And those deadlines are rapidly approaching.
The New York LLC Transparency Act (NYLLCTA), which is modeled after the CTA, takes effect on Jan. 1, 2026. This means that any new LLCs formed in New York or qualified to do business in New York on or after Jan. 1, 2026 will have 30 days to comply with the reporting requirements of the NYLLCTA. LLCs formed in New York or qualified in New York prior to January 1, 2026 will have until Jan. 1, 2027 to comply.
As outlined in our prior alert, covered LLCs must disclose each beneficial owner’s and applicant’s: full legal name; date of birth; current home or business street address; identification number from a passport, state driver's license or state identification card or document; OR a statement of exemption, including the specific exemption claimed and the facts on which the exemption is based to the New York State Department of State.
New York became the first state to impose its own corporate transparency requirements in 2023 when Gov. Kathy Hochul signed the NYLLCTA into law. In March 2024, she signed a chapter amendment (Senate Bill S8059) that set deadlines and removed a requirement that the data be made publicly available.
The legislation authorized the New York Secretary of State to promulgate regulations necessary for implementation, but to date, no regulations have been released.
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