Updated July 2026. State beneficial ownership laws are still rare. The federal BOI rule no longer applies to U.S.-formed companies, and most states have not created their own replacement. New York is the main active state law to know, and even that law currently applies only to non-exempt LLCs formed under foreign-country law and authorized to do business in New York.
That means most U.S.-formed LLCs and corporations do not have a state BOI report to file right now. But state rules are separate from FinCEN, so the safest move is to check the state where your company is formed or authorized before paying for any filing.
The short answer: New York is the only active CTA-style state law
| State / category | Active BOI-style filing in 2026? | What it means |
|---|---|---|
| New York | Yes, limited | Applies to non-exempt LLCs formed under foreign-country law and authorized in New York. |
| California | No active SB 1201 filing duty | SB 1201 did not become current 2026 filing law. |
| Other states with proposals or discussion | No current filing duty from discussion alone | Pending or failed bills are not filing requirements. |
| All other states | No CTA-style BOI filing found | Normal annual reports or business filings may still apply. |
The practical answer is not “every state is copying FinCEN.” It is closer to this: New York has a narrow state rule, California considered one, and most states have no active beneficial ownership disclosure filing.
Why state BOI rules matter after the FinCEN change
FinCEN’s March 26, 2025 interim final rule removed U.S.-formed entities and U.S. persons from federal BOI reporting. Our Corporate Transparency Act explainer covers that federal timeline in detail.
But states can still create their own disclosure laws. That is why business owners keep seeing mixed warnings. One page says U.S. companies are exempt. Another says New York has a transparency act. Both can be true since they are different systems.
State beneficial ownership laws by state in 2026
New York
New York’s LLC Transparency Act is the active state law. Current Department of State guidance says it applies to non-exempt LLCs formed under foreign-country law and authorized to do business in New York.
That is narrower than many older summaries claimed. New York-formed LLCs do not file under the current scope. LLCs formed in another U.S. state or U.S. territory do not file either.
California
California SB 1201 is a common source of confusion. It was discussed as a state version of the Corporate Transparency Act, and some older pages still rank for it. But it is not an active 2026 beneficial ownership filing requirement.
If you operate in California, do not treat old SB 1201 explainers as a filing deadline. Check the California Secretary of State for current business filings instead.
Other states with proposals or discussion
Other states may discuss ownership-disclosure bills later. That does not create a filing duty. A proposal, article, committee hearing, or trade-association warning is not the same as an enacted and effective law.
States with no active BOI filing duty
Most states still have normal business filings, such as annual reports, franchise tax reports, or statements of information. Those are not the same as beneficial ownership reports. Do not confuse a regular state maintenance filing with a BOI-style owner disclosure.
What New York actually requires
For the narrow group covered by New York, the filing is handled through the New York Department of State. A non-exempt foreign-country LLC authorized in New York files a beneficial ownership disclosure statement. An exempt company files an attestation of exemption.
Existing covered LLCs authorized before January 1, 2026 have a December 30, 2026 deadline. New covered LLCs authorized on or after January 1, 2026 file within 30 days after filing the application for authority. The filing fee is $25.
For the full state-specific breakdown, read our New York LLC Transparency Act guide.
What California SB 1201 means now
California SB 1201 is best read as a warning about stale compliance pages. The bill raised real state-level transparency questions, so older law-firm and compliance pages still appear in search. But a search result about a bill is not the same as an active filing duty.
As of July 2026, do not file a California beneficial ownership report under SB 1201. Use current California Secretary of State instructions for ordinary business filings, and wait for an enacted law before acting on BOI-style disclosure warnings.
Federal BOI vs state BOI: they are not the same
| Question | Federal BOI | State BOI / beneficial ownership law |
|---|---|---|
| Filing destination | FinCEN | State agency, such as New York Department of State |
| U.S.-formed companies in 2026 | Exempt federally | Usually no state BOI filing; check state law |
| Main current filer | Foreign reporting companies | New York foreign-country LLCs, subject to exemptions |
| Deadline source | Federal rule | State statute / agency guidance |
| Same as annual report? | No | No |
A company may have no federal BOI duty and still need to watch state law. But the reverse is true too. A state headline does not mean every domestic business is back in scope.
Wondering how the state rules line up against the federal requirement? Our comparison of state transparency laws vs the federal CTA shows which of the two regimes actually reaches your company.
What should a U.S.-formed business owner do?
If your company was formed in the United States, start from this baseline: you do not file federally, and you probably do not have a state beneficial ownership filing either.
Before paying anyone, ask where your company was formed, whether it is authorized to do business in New York, and whether the warning came from an official state page or a vendor. If the source is not official, slow down. Scammers and stale filing sites still use BOI penalty language to sell unnecessary filings. Our BOIR exemptions guide can help you sort the federal side before you act.
Which states have beneficial ownership laws in 2026?
New York is the main active CTA-style state beneficial ownership law in force in 2026. Its current scope is narrow: non-exempt LLCs formed under foreign-country law and authorized in New York. Most states do not have an active BOI-style filing requirement for domestic U.S. companies.
Does California have a BOI reporting law?
No active California BOI filing duty from SB 1201 is in effect in 2026. Older pages may discuss California’s proposed state version of the Corporate Transparency Act, but a bill discussion is not a filing requirement. Always check current California Secretary of State guidance before acting.
Do I have to file state BOI if FinCEN says I am exempt?
Usually no, but state law is separate from federal law. FinCEN’s domestic-company exemption means you do not file federally if your company was formed in the U.S. New York’s narrow rule is the main state exception to check if a foreign-country LLC is authorized there.
Are state BOI reports the same as annual reports?
No. Annual reports, franchise tax reports, and statements of information are regular state maintenance filings. Beneficial ownership reports identify people who own or control a company. A business may owe a normal annual report without owing any BOI-style beneficial ownership disclosure.
Could more states add BOI rules later?
Yes. States can pass new disclosure laws in the future, especially if lawmakers want a state-level substitute after FinCEN narrowed the federal rule. But you should not act on a pending bill. Wait for an enacted law, an effective date, and official agency instructions. The bottom line State beneficial ownership laws are not a nationwide replacement for federal BOI reporting. As of July 2026, most U.S.-formed businesses file nothing federally and have no state BOI filing either. New York is the active state law to watch, and its current scope is limited to foreign-country LLCs authorized there. If your company was formed abroad and registered in a U.S. state, BOIR Submission Center can help you sort out the federal BOI side before you act.
Sources
- FinCEN: Beneficial Ownership Information Reporting — https://www.fincen.gov/boi
- Federal Register: Beneficial Ownership Information Reporting Requirement Revision and Deadline Extension — https://www.federalregister.gov/documents/2025/03/26/2025-05199/beneficial-ownership-information-reporting-requirement-revision-and-deadline-extension
- New York Department of State: Beneficial Owner Disclosure — https://dos.ny.gov/beneficial-owner-disclosure
- New York Department of State: Beneficial Ownership Disclosure FAQ — https://dos.ny.gov/beneficial-ownership-disclosure-frequently-asked-questions
- California SB 1201 bill status — https://calmatters.digitaldemocracy.org/bills/ca_202320240SB1201
- Pillsbury: NYS LLC Transparency Act Becomes Effective — https://www.pillsburylaw.com/en/news-and-insights/nys-llc-transparency-act-effective.html
- ABA Business Law Today: Beneficial Ownership Reporting and the New York LLC Transparency Act — https://businesslawtoday.org/2025/12/what-fresh-hell-can-this-be-beneficial-ownership-reporting-new-york-llc-transparency-act/
