What is the NY LLCTA?
The New York LLC Transparency Act mirrors certain provisions of the federal Corporate Transparency Act at the state level. It requires LLCs that are formed outside the United States and registered to do business in New York to disclose their beneficial owners to the New York Department of State.
Who must comply?
The NY LLCTA currently applies to:
- Foreign LLCs formed outside the United States that are registered to do business in New York
- Both new registrations (after January 1, 2026) and existing foreign registrations
Domestic LLCs (formed in New York) and LLCs formed in other U.S. states are not currently subject to the same disclosure requirements under this law.
What information must be disclosed?
Covered LLCs must disclose:
- The name and address of each beneficial owner
- Each beneficial owner's date of birth
- Identifying information from a government-issued ID
A beneficial owner is generally defined as any individual who owns 25% or more of the LLC's membership interests, or who exercises substantial control over the LLC.
Five steps to get ahead of the NY LLCTA
- Determine if your LLC is covered — Confirm whether your LLC was formed outside the United States and is registered in New York. If so, you are subject to the NY LLCTA.
- Identify your beneficial owners — Map out all individuals who own 25% or more of your LLC or who exercise substantial control.
- Gather required documentation — Collect government-issued ID information for each beneficial owner. This may include passports or national identity cards.
- File your disclosure — Submit the beneficial ownership disclosure to the New York Department of State through the official filing process.
- Update when ownership changes — Any change in beneficial ownership must be reported within 90 days of the change.
How this differs from the federal CTA
The federal Corporate Transparency Act (CTA) requires BOI reporting to FinCEN at the federal level. Under the current Interim Final Rule (March 2025), only foreign reporting companies must file with FinCEN. The NY LLCTA is a separate, state-level requirement administered by the New York Department of State — not FinCEN.
If your foreign LLC is registered in New York, you may need to comply with both the federal CTA and the NY LLCTA separately.
Resources
SingleFile regularly publishes updates on the NY LLCTA and related compliance requirements. See our blog post: NY LLCTA & BOI: What New York Businesses Need to Know vs. Federal CTA.
For webinar recordings and detailed PDF guidance, contact us at hello@singlefile.io.