Owners of U.S. companies assessing disclosure obligations should consider not only federal requirements, but also state-level registration and reporting regimes—and monitor state developments closely. While the CTA’s BOI reporting regime has been sharply narrowed in practical effect and—at present—primarily applies to foreign entities registered to do business in the United States (“foreign reporting companies”), jurisdiction-level disclosure regimes remain. In a number of places, those regimes can functionally resemble “beneficial owner” or “control person” disclosure, even if they are not labeled the same way or are triggered by different events (for example, entity-registration or business-licensing requirements). Washington, D.C. is a notable example of these analogous transparency measures. Washington, D.C. is a notable example because its entity-registration framework goes beyond listing a registered agent or basic officer information. In connection with required filings (including the biennial report) D.C. can require disclosure of individuals with direct or indirect legal or beneficial ownership above specified thresholds, as well as certain control persons, as part of maintaining an entity’s registration and good standing.California is another (though it operates more as a “control person” regime than a CTA-style beneficial ownership regime): California’s periodic Statement of Information requires disclosure of the LLC’s manager(s) (or, if member-managed, its member(s)), including addresses.
New York is also worth flagging. The New York LLC Transparency Act (effective January 1, 2026) establishes a state-law beneficial ownership reporting framework for LLCs—requiring either a beneficial ownership filing or an attestation of exemption that is conceptually similar to the CTA. At the same time, it is narrower in scope, focusing on non-U.S. LLCs authorized to do business in New York, rather than the broader universe of small domestic entities.

For more information: Francesca Giannoni-