• New York LLCs: No new state level beneficial ownership filings are currently required.
• U.S. formed LLCs registered in New York: No additional New York transparency filings are expected at this time.
• Foreign LLCs registered in New York: You may be required to report ownership information beginning in 2026 or 2027, depending on your registration date.

The veto avoids creating a separate New York reporting system that would have gone beyond federal requirements. While this reduces compliance burdens for most small businesses and nonprofits, it also means New York may revisit transparency legislation in future sessions, particularly as federal rules continue to evolve.

Business owners should stay informed but not alarmed. For now, compliance obligations are limited and focused on a narrow group of entities. If you operate through a foreign LLC or are considering forming one, early planning can help avoid last-minute compliance issues.

Effective as of March 26, 2025, U.S formed entities (formerly “domestic reporting companies”) and their beneficial owners no longer need to report Beneficial Ownership Information (BOI) to FinCEN under the Corporate Transparency Act.

Under FinCEN’s interim final rule, the term “reporting company” now applies only to certain foreign entities registered to do business in the United States. U.S. persons are not required to report BOI for these foreign entities, and penalties will not be enforced against U.S. citizens or former domestic reporting companies. For full details or to submit BOI filings, visit fincen.gov.

For help with small businesses, not-for-profit organizations, and HDFCs, or questions about corporate transparency, contact the Community Development Project at 212-298-3340, CommunityDevProject@legal-aid.org, or complete our online intake form.

The information in this document has been prepared by The Legal Aid Society for informational purposes only and is not legal advice. This information is not intended to create, and receipt of it does not constitute, an attorney-client relationship. You should not act upon any information without retaining professional legal counsel.