New York Cracks Down on Non-U.S. LLCs With New Beneficial Ownership Disclosure Law

By Eric Geringswald | CSC

Non-U.S. LLCs Must Now Disclose Beneficial Ownership in New York

The New York LLC Transparency Act (NY LLCTA) requires non-U.S. limited liability companies registered to do business in New York disclose their beneficial ownership information and file annual statements or attest to exemptions. The Act took effect on January 1, 2026.

This enforcement mechanism underscores the state's intent to ensure transparency and accountability in LLC operations, preventing illicit uses of shell companies such as money laundering or other hidden criminal activity. It was modeled after the federal Corporate Transparency Act (CTA), although it’s more limited in scope, applying only to limited liability companies.

LLCs that fail to comply with the new legislation could face investigations by the New York State Attorney General and fines of up to $500 per day for non-compliance.

The Spring 2026 edition of CSC’s New York Laws Governing Business Entities Annotated includes a new Appendix that outlines the evolving requirement for specific limited liability companies to disclose individual owner details to the New York Department of State. The Appendix provides an overview of the requirements, a list and description of exemptions, and images of the forms used for filings related to the new legislation.

A Comprehensive Resource

New York Laws Governing Business Entities Annotated is the resource legal practitioners need to stay on top of legal developments and court decisions in the state.

The Spring 2026 edition captures the latest legislative changes through Chapter 89 of the 2026 New York State legislative session. More than 50 sections have been added or amended since the Fall 2025 Edition.

Our Legislative Analysis summarizes important changes made to the law, while Blackline Amendment Notes following each amended section indicate the exact text added or deleted by the Legislature. The Table of Sections Affected lists all statutory changes.

The Spring 2026 edition includes two dozen new case notes from New York state and federal courts interpreting the law added since the Fall 2025 edition. Also included are four new full text cases covering recent legal developments concerning appraisal actions, LLC management, LLC membership, and stock. The Table of New Annotations lists new case notes, and new notes are marked in the text with gray bars.

More than 100 fillable New York forms for incorporation/formation, qualification, mergers, dissolution, and name reservation for all entity types are available on the LexisNexis Store online download center. A listing of the forms can be found in the book’s forms appendix. Up-to-date Publication and Fee Tables provide a snapshot of fees and publication requirements for the different entities.

The Spring 2026 Edition of New York Laws Governing Business Entities Annotated is available as a two-volume softbound book or as an eBook, compatible with dedicated eReader devices, computers, tablets, and smartphones that use eReader software or applications. 

This title, along with many others, is available on the LexisNexis Digital Library.

To learn more about the Spring 2026 Edition of New York Laws Governing Business Entities Annotated, call 1.800.533.1637 or visit us online at www.lexisnexis.com/csc.