Effective as of January 1, 2026, there are now filing requirements for certain non-U.S. limited liability companies (LLCs). These new requirements apply only to limited liability companies formed under the laws of a foreign country that are authorized to do business in New York.
The Limited Liability Company Law was amended to require non-U.S. LLCs authorized to do business in New York to file beneficial ownership disclosure statements with the Department of State. These filings provide basic information about the individuals who own or control the company.
LLCs that are authorized to do business in New York and filed for such authorization on or after January 1, 2026, must file either a beneficial ownership disclosure statement or attestation of exemption within 30 days of filing an application for authority with the New York Department of State.
LLCs that were authorized to do business in New York before January 1, 2026, must file either a beneficial ownership disclosure statement or attestation of exemption by December 31, 2026.
If you have any questions and would like to speak with an attorney about this new requirement, please contact Lacy Katzen LLP for a consultation today.
You can find guidance from New York State on its website.
