On March 1, 2024, New York Governor Kathy Hochul signed into law
a new, amended version of the New York LLC Transparency Act (NYTA),
replacing the original version that was enacted back in December
2023 (see our prior Alert). The new NYTA will, similar to the
original NYTA, require all limited liability companies (LLCs) that
are either formed under New York law or that are or seek to be
authorized to do business in the state of New York to submit
information to the New York Department of State (NYDOS) disclosing
the entity's beneficial owners, unless the entity qualifies for
an exemption from such requirements.
The effective date of the new NYTA is January 1, 2026 (a year
later than the proposed effective date under the original NYTA).
LLCs that are formed in New York or qualified to do business in New
York prior to January 1, 2026, will therefore have until January 1,
2027, to make their initial filings. LLCs formed or qualified in
New York after January 1, 2026,