New York LLC Transparency Act (NY LLCTA)
As a proven leader in Corporate Transparency Act (CTA) compliance, SingleFile will provide guidance and intelligent workflow for businesses to comply with the New York LLC Transparency Act (NY LLCTA), which goes into effect on January 1, 2026.
While the final details haven’t been released by the state yet, we can help set the table so that you can be ready as new details emerge and the NY LLCTA goes into effect.
Key Filing Deadlines
Foreign LLCs (formed outside of the US, authorized in New York), the following deadlines applied:​
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LLCs formed or authorized on or before January 1, 2026 must file by January 1, 2027.
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LLCs formed or authorized after January 1, 2026 must file within 30 days of the filing of articles of organization or an application for authority to do business.
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After the initial filing, the NY LLCTA requires an annual statement that either confirms or updates the beneficial ownership information (BOI) or attestation of exemption.
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What Is the NY LLCTA?
Effective January 1, 2026, the NY LLCTA will require all LLCs formed outside of the United States that are authorized to do business in New York to submit to the New York Department of State either 1) Beneficial Ownership Information (BOI) report or 2) an attestation of the exemption claimed. The contents of the BOI and specific exemptions are similar in scope to the federal CTA, but the NY LLCTA differs in significant aspects:
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Only applies to LLCs registered in NY
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Exempt entities must file
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Annual updates are required (including for exempt entities)
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All BOIs must include Company Applicant information
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The window for filing after forming or registering LLCs in New York is 30 days.
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No requirement to provide an image of government identification
Who Must File?
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Foreign LLCs (formed elsewhere, authorized in New York) will need to submit BOI unless exempt.
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Exempt entities must file a formal attestation of exemption under penalty of perjury. The report
for exempt and non-exempt entities must be updated or confirmed on an annual basis.
What Must Be Reported?
Beneficial Ownership Information (BOI) filings must include the following for both beneficial owners and applicants (where applicable):
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Full legal name
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Date of birth
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Current street address (home or business)
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Unique ID number (e.g., driver’s license or passport)
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Unlike the CTA, NY does not require submitting images of ID documents, nor does it provide for FinCEN identifiers or an equivalent.
Annual Reporting Obligation
After the initial filing, LLCs—whether reporting or exempt—must submit an annual statement confirming or updating:
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Beneficial ownership details
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Principal office address
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Exemption status (if applicable)
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Any additional information as required by NY DOS
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Privacy & Access Controls
Beneficial ownership data will be kept confidential, accessible only under tight conditions:
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By court order,
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With consent from the beneficial owner or
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To authorized government or enforcement agencies.
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Penalties for Non-Compliance
Failure to file can result in:
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Past due status after 30 days; delinquent status after two years,
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Civil penalties up to $500 per day and/or
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Risk of suspension, dissolution, or revocation of authority to do business in New York.
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Why SingleFile?
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Proven leadership in guiding clients through the federal CTA compliance and transition in 2024 and beyond
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Robust platform and industry-leading workflows with a playbook tailored to state and federal BOI requirements
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Proactive monitoring of NY LLCTA developments—ready to adapt as details evolve
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Streamlined user experience—secure, accurate, and deadline-driven
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High-touch support for onboarding, filings, annual updates, and audit readiness
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Let SingleFile help you navigate this uncertain and emerging regulatory regime so you can focus on more important things like running your business.
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Five Steps to Get Ahead —
the SingleFile Advantage
SingleFile recommends preparing with these five foundational steps:
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1. Assess eligibility: Determine whether your LLC must file or can claim exemption.
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2. Identify key individuals: Pinpoint beneficial owners and applicants.
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3. Collect BOI data: Securely gather the required personal and government ID information.​
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4. Implement an annual reporting system: Assign responsibilities and set reminders.
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5. Leverage expert support: Use SingleFile’s compliance platform and guidances to facilitate the collection of sensitive information, keep such information safe, streamline filings and stay in control.
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​ADDITIONAL DETAILS
To stay up-to-date with NY LLCTA, visit the New York Department of State website at dos.ny.gov.