New York’s LLC Transparency Law Takes Effect January 1, 2026
Effective January 1, 2026, New York’s LLC Transparency Act imposing beneficial ownership reporting on New York LLCs and foreign LLCs authorized to do business in New York goes into effect. Despite the interim final rule (IFR) issued by the Financial Crimes Enforcement Network (FinCEN) in March 2025 revising the definition of “reporting company” for purposes of the federal Corporate Transparency Act (CTA) exempting entities formed under the laws of a U.S. state or tribal authority from reporting under the CTA, the New York Limited Liability Company Transparency Act (NYLLCTA) survives and will go into effect on January 1, 2026 . The NYLLCTA applies to both limited liability companies (LLC) formed in the state of New York or LLCs formed in any other state (foreign LLCs) that are registered to do business in the state of New York. As a result, LLCs formed under New York law or registered to do business in New York (each a “reporting company) must file either the required beneficial ownersh...