Beneficial Ownership Reporting: What New York Business Owners Need to Know
Key Takeaways
- Most LLCs and corporations that have elected S-corporation tax status are not currently required to file a Beneficial Ownership Information (BOI) report.
- Foreign LLCs authorized to do business in New York may still be required to report
- New York’s LLC Transparency Act is in effect, but much narrower than initially proposed
- Reporting rules can change, so preparation matters even if no action is required today
If you’ve been trying to follow the conversation around beneficial ownership reporting, you’re not alone if it’s felt confusing. Between federal rules, proposed state laws, and late-year changes, many business owners aren’t sure what applies or whether they need to do anything at all. Here’s a straightforward update on where things stand today and what to keep on your radar.
Why Beneficial Ownership Reporting Exists
Beneficial ownership reporting stems from the federal Corporate Transparency Act, which was passed to increase transparency around who owns and controls certain business entities. The intent is regulatory oversight, not public disclosure or taxation.
Over time, both federal and state governments have explored ways to expand these requirements, which is where much of the confusion has come from.
Where the Rules Land Today
At the federal level, beneficial ownership reporting is currently limited to foreign-formed entities registered to do business in the United States. Domestic U.S.-formed LLCs and corporations are not required to file at this time.
New York took a similar path. While the state’s LLC Transparency Act went into effect on January 1, 2026, a late-2025 veto significantly narrowed its reach. As a result, the law applies only to foreign LLCs authorized to operate in New York, not to New York-formed or other U.S.-formed LLCs.
For most closely held businesses in New York, this means no immediate filing obligation under either federal or state rules.
What Business Owners Should Do Now
Even if your business is currently exempt, this isn’t an area to ignore entirely. Beneficial ownership transparency remains a focus at both the federal and state levels, and requirements could expand again in the future.
We recommend that business owners:
- Maintain clear, accurate ownership records
- Understand how entities are structured, especially if multiple businesses or foreign affiliates are involved
- Stay informed so you can act quickly if the rules change
Businesses with more complex ownership structures may want to review their setup proactively rather than wait for a compliance deadline to appear.
How Ceschini Can Help
Our role isn’t just to help you react to new rules; it’s to help you understand how they fit into the bigger picture of compliance, tax planning, and business operations. If you’re unsure whether these reporting requirements apply to you now or how future changes could affect your business, we’re happy to walk through it with you.
