New York LLC Transparency Act Reporting for Small businesses

Home > Guides > Corporate Transparency Act

Disclaimer

 This guide addresses the basic reporting requirements for most small businesses under the New York LLC Transparency Act. It does not include every consideration. This guide was last updated on December 15, 2025 and some of the information may have since changed. The information in this guide is not legal advice and is not intended to be relied upon as legal advice. If you have a legal issue, you should not rely on this information and instead speak to an attorney.

The Basics 

• Most limited liability companies need to report information about the business and its “beneficial owners” to the New York Department of State.

• Exempt businesses must file attestations of exemption.

• As of 12/15/25, New York State has not yet made the filing system or reporting instructions available.

• As of December 15, 2025, the rule applies only to LLCs formed outside the United States. However, we expect Governor Hochul to sign Senate Bill 8432 soon, which would extend the requirement to all LLCs registered in New York.

• “Beneficial owners” are individuals who exercise substantial control over the company or own or control 25% or more of the ownership interests of the company.

• If the business was created before January 1, 2026, the business must file the “Beneficial Ownership Information” report by January 1, 2027.

• If the business is created after January 1, 2026, it has 30 days to report.

• The report must include the following information about the business:

  • The business’s full name;

  • Any trade names the business uses: their registered d/b/a (“doing business as”) and names used informally;

  • The business’s street address;

  • The state of formation; and

  • The business’s EIN/TIN.

• The report must include the following information about beneficial owners:

  • Full legal name;

  • Date of birth;

  • Complete residential address;

  • The unique identifying number from one of the following nonexpired documents: a state-issued driver’s license, a US passport issued by the US government, a state, local government, or Indian tribal identification document issued for the purpose of identifying the individual, or a foreign government-issued passport, if the individual does not have any of these other documents; and

  • an image of the identification document bearing the unique identification number.

• Any changes to the information reported must be reported within 30 days of the change.

• All LLCs formed or registered to do business in New York are required to file an annual statement.

Consult a Small Business Attorney

An experienced attorney can determine your business’s specific responsibilities and advise you about how to efficiently meet them. Contact Pepitone Law for a consultation.