With less than a month before the New York LLC Transparency Act (NY LLCTA) is scheduled to take effect (January 1, 2026), the situation remains uncertain. The amendment passed by the Legislature—intended to significantly narrow the law—is still unsigned by the Governor. New York agencies have not released updated guidance or implementation rules.
This leaves businesses in a difficult position: no final amendment + no updated regulations + a rapidly approaching effective date.
Even in this murky environment, there are practical steps NY LLCs can—and should—take to be ready.
Know the Two Possible Outcomes
A. If the Amendment Is Not Signed
The law would align closely with the federal Corporate Transparency Act (CTA), applying only to international companies that have foreign qualified by filing in the United States (in this case NY), not domestic NY LLCs.
This would virtually eliminate reporting for the vast majority of New York LLCs.
B. If the Amendment Is Signed
The Amended language will take effect. That means:
- All active domestic and foreign LLCs doing business in NY must file a Beneficial Ownership Disclosure (BOD) or Exemptions.
- Reporting requirements would be separate from, but similar to, FinCEN CTA BOIR filings.
- There will be new potential penalties for failure to file
- Applicants will need to be reported
- Non-exempt LLCs would need to provide:
- Beneficial owners
- Required ID documents Information
- Exemptions, if applicable
Because the outcome is unresolved, businesses should plan for either scenario.
Gather Beneficial Ownership Information Now
In the Event that the amendment is eventually signed, collecting this information puts you ahead for:
- NYLLCTA compliance
- Potential NY filings
- Lender or bank requests
- Licensing applications
- Internal recordkeeping
Have on hand:
- Legal names
- Residential addresses
- Dates of birth
- ID (passport or driver’s license)
- Ownership percentages
- Individuals with substantial control
If the amendment fails, you will likely have no obligations under the law as is. If it passes, you’re positioned to comply within the required timelines – to avoid any potential penalties.
Be Prepared for a January Filing Window
If the Amended law goes into effect:
- Existing LLCs get one year to file their BOD or Exemption (through Dec 31, 2026)
- Newly formed LLCs must file their BOD or Exemption within 30 days of formation
New York could also release emergency guidance near the deadline—so staying flexible is key.
Monitor Only Trusted Sources regarding the NY LLCTA
There is a lot of incorrect or speculative information circulating—especially claims that “the law only applies to international LLCs.”
That statement appears to be true, Unless the pending amendment is signed.
Until then, the original law remains on the books.
Track updates from:
- The NY Department of State
- The NY Senate and Assembly websites
- Trusted compliance providers like Accumera
- Governor’s official communications
- Legal industry alerts
Have a Filing Partner Ready (Just in Case)
If the amendment is signed, there will be a rush in early 2026. LLCs should plan now so they’re not scrambling later.
Accumera can assist with:
- Helping you understand the possible exemptions (so YOU can determine if they apply to you)
- Preparing beneficial ownership disclosures (BOD)
- Filing reports with New York (if required)
- Ongoing compliance/maintenance
- Multi-state guidance for clients with entities in multiple jurisdictions
Don’t Panic—Just Prepare
The most important point: nothing needs to be filed today for the New York LLC Transparency Act, but you should be gathering your information and watching developments.
Preparation ensures you’re compliant, no matter what happens with the amendment.
If you have any questions or other needs, please don’t hesitate to Contact US!
