NEW YORK’S LLC TRANSPARENCY ACT GOES INTO EFFECT
February 25, 2026
Eckert Seamans has prepared the information in this update for educational purposes only. It does not constitute legal advice nor substitute for legal advice. Neither your receipt of information from this website nor your use of this website to contact Eckert Seamans or one of its attorneys creates an attorney-client relationship, as the firm may, for example, already represent another party involved in your matter. Accordingly, you should not provide confidential information to Eckert Seamans. Persons seeking legal advice should consult a licensed professional attorney in their state. The firm’s Terms of Use, Legal Notice, and Disclaimer detailed herein are expressly incorporated into the Aviation Regulatory Update.
After being modeled on the federal Corporate Transparency Act, the New York LLC Transparency Act (the “Act”) became effective on January 1, 2026. Due to New York Governor Kathy Hochul vetoing additional requirements last month, the Act now only applies to non-U.S. limited liability companies that have registered to do business in New York. Those LLCs formed outside the U.S. and authorized to do business in New York must file their initial beneficial ownership information report by December 31, 2026. Even those foreign LLCs which may qualify for an exemption must file an attestation of exemption under penalty of perjury. Foreign LLCs authorized to do business in New York should consult with counsel to evaluate whether they ought to comply and, if so, how to comply in the absence of regulatory clarity. Failure to comply with the Act could result in penalties of up to $500 for each day of noncompliance, and, in more extreme cases of prolonged failures to file, the suspension of noncompliant foreign LLCs.
This Aviation Blog post is intended to keep readers current on developments in the law. It is not intended to be legal advice. If you have any questions, please contact Evelyn Sahr at 202.659.6622 or esahr@eckertseamans.com; Drew Derco at 202.659.6665 or dderco@eckertseamans.com; Tyler Myers at 202.659.6642 or trmyers@eckertseamans.com, or any other attorney at Eckert Seamans with whom you have been working.
Share This Post
Authors
