The first deadline for an existing New York LLC
The statute gives previously formed or authorized LLCs a transition period instead of applying the new-company 30-day clock retroactively.
What the official record says
LLC Law §1107(e) covers two groups. A previously formed or authorized reporting company must file the beneficial ownership disclosure. A previously formed or authorized exempt company must file the attestation described in subdivision (b). The statute’s effective-date note states January 1, 2026. The transition date does not eliminate the need to determine which submission applies, and exempt companies are expressly included.
What to check on the document
Confirm that the LLC existed or was authorized before the effective date. Then separate the first transition filing from other New York maintenance filings.
- Verify the formation or authority date in the Department of State record.
- Determine whether the federal-linked definitions point to reporting-company disclosure or exemption attestation.
- Keep the transparency confirmation separate from the LLC’s biennial statement and tax records.
How to use the result
A worksheet can calculate the transition date and lay out the required fields, but it should not present a grey exemption question as settled. The owner makes the filing in the DOS portal. After the initial submission, §1107(g) requires annual confirmation or updating, so the transition filing begins a recurring record rather than closing the issue permanently.
The worksheet maps the facts you provide to the words of LLC Law §1107 and marks any grey box for counsel. It does not decide a hard legal question. The filing belongs in the Department of State portal under the LLC owner’s control, with sensitive owner fields completed there rather than sent to us.
Operated by Reality Contact, LLC. Reality Contact, LLC is not a law firm and this is not legal advice. We do not file with DOS; you file. We collect no ID numbers, dates of birth, or home addresses.