Does my New York LLC have to file under the LLC Transparency Act, and by when?

§What the statute says

The New York LLC Transparency Act is Article XI of the Limited Liability Company Law. The federal beneficial-ownership rule it was modelled on was switched off for domestic companies in March 2025, which is why many owners believe the whole idea went away. The New York filing did not go away. These are the operative sentences, quoted from the Senate's published text.

LLC Law §1107, effective January 1, 2026 — new LLCs

"Within thirty days of an initial filing of articles of organization or an application for authority pursuant to this chapter, a reporting company shall file with the department of state a beneficial ownership disclosure."

§1107 — LLCs that already existed

"Within one year of the effective date of this section, all previously formed or authorized reporting companies shall file with the department of state a beneficial ownership disclosure."

§1107 — exempt companies file too

"All exempt companies shall electronically file, under penalty of perjury, an attestation of exemption in such form designated by the department of state."

§1107 — every year after

"Once the initial beneficial ownership disclosure has been filed, all reporting companies shall electronically file with the department of state an annual statement confirming or updating" the information.

nysenate.gov/legislation/laws/LLC/1107

LLC Law §1108 — what happens after the date

"A reporting company which has failed to file its beneficial ownership disclosure, attestation of exemption, or annual statement as required by this article for a period exceeding thirty days shall be shown to be past due."

"The attorney general may assess a fine of up to five hundred dollars for each day the company has been past due."

The past-due mark is removed on filing the current statement and "the payment of a fine of two hundred fifty dollars." A company that fails to file its disclosure or attestation "shall be deemed suspended."

nysenate.gov/legislation/laws/LLC/1108

So an LLC formed before 2026 files by January 1, 2027; an LLC formed in 2026 files within thirty days of its articles; and an exempt LLC still files an attestation. Every New York LLC files something.

1Who this is for

This page is for the person who owns or manages a New York LLC and has just heard about the deadline: the one-member consulting LLC, the LLC that holds a rental building, the restaurant, the LLC a friend set up for a side business in 2019 and forgot about. It is also for the accountant or bookkeeper who keeps the books for twenty of those and would rather hand each client a finished worksheet than explain the statute twenty times.

You do not need to know whether you are a reporting company before you write to us. That is the question we answer.

3What you get

The free check is one email: the LLC as it appears in the DOS record, whether the statute reads it as a reporting company or exempt from what you have told us, and the date your first filing is due. If we cannot tell from the public record and your description, the email says which fact decides it.

The $19 pack arrives within one business day of your answers to a short questionnaire about how the LLC is owned and managed. It contains three pages.

• A determination page that walks your stated facts against the statute's exemption list, quoting the statute, with any grey box marked "take this to counsel" rather than decided.
• The beneficial-ownership worksheet laid out in the same order as the DOS filing, so the online filing is a transcription. The identifying fields for each owner (ID number, date of birth, home address) are left blank for you to fill in at the portal. We never see them.
• The deadline page: your filing date, the annual-statement cycle that follows, and the §1108 figures quoted above.

The $49 tier adds the annual-statement calendar and a re-issued worksheet each year showing what changed since your last filing. The $199 tier is the pack for up to twenty entities from one spreadsheet, with one index sheet, for an accountant's book.

4How it works

You type the LLC's name into the form above and we read its DOS record. Within one business day you have the free answer by email. If you want the pack, you reply and pay, we send the questionnaire (ownership structure, management, whether the company is itself owned by an exempt entity, and similar facts; no ID numbers), and within one business day of your answers the pack is in your inbox. You then sign in to the Department of State's portal and file it yourself. We do not touch the portal, and any fee the state charges at the portal is paid to the state, not to us.

5Prices

6Why it costs what it costs

You are not paying us for the filing; the filing is your act at the DOS portal. What people pay for is knowing whether they have to file, and having the worksheet filled in the right order so the portal takes ten minutes instead of an evening. Registered agents and formation services sell that as part of their agent service, and attorneys do it by the hour; the range we have seen is roughly $100 to $500 from agents and $300 to $750 from attorneys, though their pricing pages would not load for us this week, so treat those as the range we have observed rather than quotes. A $19 worksheet with a refund if the form changes under you is the price at which it is easier to buy than to read the statute yourself, and that is the point of it.

8Questions people ask

Didn't the beneficial-ownership requirement get repealed?

The federal one did, for domestic companies, by an interim final rule in March 2025. New York's requirement is a state statute, LLC Law §1107, and it took effect on January 1, 2026. It is separate and it is in force.

My LLC has one member and owns one building. Surely it is exempt?

Probably not, but we check rather than assume. The exemptions track the federal list, which is mostly regulated entities (banks, insurers, registered investment companies and the like) and large operating companies; a small, privately held LLC usually comes out as a reporting company. If your facts land near an edge, the determination page says so and names the fact that decides it.

I formed the LLC in 2026. When is it due?

Thirty days from the initial filing of your articles of organization, per §1107. The free check gives you the date from the DOS record.

Is this the biennial statement?

No. The biennial statement is a different, older DOS filing. This is the beneficial-ownership disclosure (or attestation of exemption) under Article XI, and then an annual statement after it. If you want every date your LLC owes in every state it is registered in, say so in the form and the reply will include that calendar.

What if I miss it?

§1108, quoted above: thirty days after the due date the company is shown as past due; the Attorney General may assess up to $500 a day; a $250 fine and the current filing remove the past-due mark; a company that does not file is deemed suspended. We are quoting the statute, not predicting what the Attorney General will do in any case.

9Specific situations

Each of these pages answers one question in more detail, with the statute text and the form.

Which LLCs are exempt Formed in 2026: the 30-day clock Formed before 2026: January 1, 2027 Penalties under §1108 The annual statement For accountants with a book of NY LLCs