The New York LLC Transparency Act (NY LLCTA) officially took effect on January 1, 2026. While the original legislation was designed to mirror the broad disclosure requirements of the federal Corporate Transparency Act, recent legislative updates and a significant gubernatorial veto have drastically narrowed its scope. For New York practitioners, the result is clear: All U.S.-formed entities, including New York PLLCs, are currently exempt from the Act’s beneficial ownership reporting requirements.

Understanding the Narrowed 2026 Scope

The NY LLCTA was intended to combat anonymous shell company activity by creating a database of “beneficial owners”—individuals who own 25% or more of an entity or exercise substantial control over it. However, following Governor Hochul’s December 2025 veto of SB S8432, the Act’s definitions remain tied to a narrowed federal framework. This means New York reporting is currently limited to foreign (non-U.S.) companies authorized to conduct business in the state.

The Domestic Exemption: Why PLLCs Are Safe

In 2026, the primary factor determining your reporting obligation is where your entity was formed. Because a New York Professional Limited Liability Company (PLLC) is a domestic entity created through a filing with the New York Secretary of State, it falls outside the Act’s current reporting scope.

Domestic Status in 2026:

Limited liability companies formed within any U.S. state or territory (including NY PLLCs) are exempt from reporting beneficial ownership information to the New York Department of State. Furthermore, these domestic entities are not required to file an “Attestation of Exemption” or any other status disclosure under the NY LLCTA.

This means your professional practice can maintain its privacy from this new state-level registry without the administrative burden of annual filings or status confirmations.

Compliance for Foreign (Non-U.S.) LLCs

While domestic firms are spared, foreign limited liability companies (those formed under the laws of a country other than the U.S.) must comply if they are authorized to do business in New York. These entities must determine if they are “Reporting Companies” or if they qualify for one of the 23 exemptions incorporated from the federal CTA.

Foreign LLC Deadlines:

Existing Foreign Entities: Those authorized before January 1, 2026, must file their initial report or attestation by December 31, 2026.
New Foreign Entities: Those authorized on or after January 1, 2026, must file within 30 days of authorization.

Penalties for Reporting Companies

For those foreign entities that are subject to the Act, the consequences of failing to file—or providing false information—are severe:

Daily Civil Penalties: Fines of up to $500 for each day a required report is past due.
Business Suspension: The state may suspend the entity’s authority to conduct business in New York.
Delinquency Status: Entities more than two years past due will be formally marked as “delinquent,” hindering legal actions and state standing.

Strategic Advantage of the NY PLLC

Choosing to form a New York PLLC rather than attempting to register a foreign (non-U.S.) entity provides immediate administrative relief. By remaining a domestic New York entity, your professional practice completely bypasses the reporting registry, saving you from the yearly burden of beneficial ownership updates at the state level.

Are you currently practicing through a non-U.S. entity? We can assist you in merging into a domestic NY PLLC to secure your exemption and ensure full compliance with New York professional practice laws.

LLC and PLLC Compliance Under the New York LLC Transparency Act: 2026 Guide to Exemptions