Beyond labor-specific laws, New York is rolling out new requirements for business owners aimed at transparency and social benefits. Two major mandates in 2026 that New York companies should note are the LLC Transparency Act and the Secure Choice retirement program:
Businesses operating as LLCs will face new disclosure obligations under the New York LLC Transparency Act, effective January 1, 2026. This law requires both domestic LLCs formed in NY and foreign LLCs registered in NY to report their beneficial owners to the NY Department of State. A “beneficial owner” generally means anyone who owns or controls a significant portion of the company. Newly formed or registered LLCs on/after Jan 1, 2026 must file a report within 30 days of formation, listing each beneficial owner’s name, birth date, address, and a photo ID number. LLCs formed before 2026 will have until December 31, 2026 to file their initial owner disclosure. Thereafter, annual updates are required to confirm or update the information on file. Failure to comply carries steep penalties – fines can accrue up to $250 per day of noncompliance after a grace period, and long-term delinquency could even jeopardize the LLC’s good standing.
In other words, if you have an LLC, mark your calendar to prepare the filing. Watch for the Department of State to release the reporting form and further guidance. Companies may want to start collecting the required info from owners now to meet the deadlines. Keep in mind this state law comes on the heels of a federal beneficial ownership reporting rule, i.e., the Corporate Transparency Act via FinCEN; thus, ensure you understand and comply with both regimes if they apply to your business.
Lastly, beginning in 2026, New York’s Secure Choice Savings Program will require many employers to either enroll in the state-run retirement savings plan or certify exemption if they already offer a qualified retirement plan, such as a 401(k). The mandate applies to New York State employers with 10 or more employees and NYC employers with 5 or more. Covered businesses must automatically enroll eligible employees into a Roth IRA, facilitate payroll deductions, and provide opt-out options—all without needing to contribute employer funds. Registration deadlines are staggered by company size, i.e., employers with 30+ employees must register by March 18, 2026; employers with 15–29 employees by May 15; and those with 10–14 by July 15. Smaller businesses like Citiline will have a later deadline around mid-2026, and should keep an eye out for the official notice from the state, which will confirm the exact deadline and provide the instructions for enrollment. To avoid penalties, businesses should review payroll capabilities, monitor for official enrollment notices, and consider whether implementing a private retirement plan may be a preferable alternative.
Outside Legal Counsel LLP can help ensure that businesses are in compliance and are fulfilling their obligations under the LLC Transparency Act, the Secure Choice Savings Program and other applicable laws. Reach out to us for a consultation about our services and this process.
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