How to Fill Out and Submit the NYC Doing Business Data Form

To complete the NYC Doing Business Data Form, you supply your entity’s identifying details, list your top three principal officers, name at least one senior manager with hands-on oversight of the city transaction, and disclose anyone who owns or controls 10% or more of the business. You then submit it one of two ways: electronically through the LL34 Compliance tab in PASSPort, or on paper returned to the city agency that handed it to you. There is no filing fee. Until the form is complete, the city will not consider your proposal or make an award.¹

Who Has to File

The form is triggered when your business dealings with the city cross dollar thresholds set by NYC Administrative Code § 3-702(18). The main triggers are goods and services contracts totaling $100,000 or more over the preceding twelve months, construction contracts totaling $500,000 or more over the same period, concessions or franchises with an estimated annual value of $100,000 or more, grants of $100,000 or more, any real property transaction with the city, any economic development agreement, and city pension fund investment contracts.² Emergency contracts and contracts awarded through publicly advertised competitive sealed bidding are excluded.

Multiple smaller dealings aggregate. Two $60,000 contracts with the same entity inside a twelve-month window combine to $120,000 and cross the threshold.² Land use applications are different: any application certified under City Charter sections 195, 197-c (ULURP), or 201 (zoning text amendments) triggers the form regardless of project size. Owner-occupants of one-, two-, and three-family homes are excluded from that land use trigger.³

What the Form Asks For

Entity Information

The top of the form captures your legal name, Employer Identification Number (EIN or TIN), business address, phone, and email. You select an entity type from a list that includes corporation, LLC, partnership, joint venture, sole proprietor, and non-profit.⁴

Principal Officers

You must list three officers or their functional equivalents:⁵

The CEO or equivalent, meaning the highest-ranking officer or manager (President, Executive Director, Sole Proprietor, Chairperson of the Board).
The CFO or equivalent, meaning the highest-ranking financial officer (Treasurer, Comptroller, Financial Director, VP for Finance).
The COO or equivalent, meaning the highest-ranking operational officer (Chief Planning Officer, Director of Operations, VP for Operations).

Each officer entry asks for full name, title, home address, home phone, and date of birth. Only names and titles become public in the database. Home address, phone number, and date of birth are kept confidential and are not used for communication.⁶

Senior Managers

At least one senior manager is mandatory. Leave this blank and the form is incomplete. A senior manager is the person who, by title or actual duties, has substantial discretion and high-level oversight of the specific city transaction. For a contract, that’s the contract manager; for a grant, the grant manager.⁶ You supply the same personal fields collected for principal officers.

Principal Owners

List anyone who owns or controls 10% or more of the entity, including stockholders, partners, and any other person with an ownership or controlling interest. Organizations holding a 10% or greater stake are reported as well.⁶

How to Submit

The submission path depends on how the agency sourced your transaction.

Through PASSPort

If your contract is sourced through the city’s Procurement and Sourcing Solutions Portal, the LL34 Compliance tab inside PASSPort replaces the paper form entirely. You complete the disclosures electronically as part of your vendor profile and the system routes them to the Mayor’s Office of Contract Services (MOCS).⁷ Most city procurement contracts move this way.

On Paper, for Non-PASSPort Transactions

For transactions sourced outside PASSPort, including small purchases, real property actions, economic development agreements, land use applications, franchises, and concessions, you fill out the paper Doing Business Data Form supplied by the agency handling your transaction.⁸ Return the completed form to that same agency. Do not send it directly to MOCS or to the Doing Business Accountability office; the agency forwards it for inclusion in the database.⁹

Either way, treat the filing as a gate. Your proposal is effectively frozen and no award will be made until the form clears.¹

Updating the Form After Changes

Filing is not a one-time event. While your city dealings are active, any change to principal officers, senior managers, or ownership needs to be reported. The form itself has a “Change” option that lets you update only the fields that have changed rather than refilling the whole document, and a “No Change” option that requires only your EIN and a signature on the last page.⁶ Once MOCS processes the update, the database reflects it.

For questions about whether an entity belongs in the database or how long it stays listed, MOCS can be reached at 212-298-0600 or DoingBusiness@mocs.nyc.gov.

Mistakes That Stall Your Submission

The most common failure is omitting the senior manager. Without at least one, MOCS treats the form as incomplete and your proposal cannot be considered.¹ The senior manager need not be a C-suite executive. It’s whoever actually oversees the specific city deal.

Another frequent error is treating PASSPort registration as a substitute for the paper form. For transactions sourced outside PASSPort, completing your PASSPort profile does not satisfy the Doing Business filing requirement.⁹ Entities also sometimes mail the completed paper form straight to MOCS instead of returning it to the originating agency, which slows processing.

One more thing to watch: the construction threshold. Many vendors assume the $100,000 cutoff is universal, but construction contracts don’t trigger the requirement until total value reaches $500,000.²

Why You’re Filing: The Contribution Limits

The form feeds the Doing Business Database, which the New York City Campaign Finance Board uses to enforce reduced contribution limits on anyone listed as a principal officer, senior manager, or principal owner. If your name goes on the form, the following per-election-cycle caps apply to your donations to city candidates:¹⁰

Mayor, Public Advocate, or Comptroller: $400
Borough President: $320
City Council: $250

These are well below the standard contribution limits. Contributions from people listed in the database are also ineligible for the city’s public matching funds program and do not count toward the threshold a candidate needs to qualify for public funds.¹¹ What matters is whether you have active city dealings on the date you make the contribution, not whether you had them at some earlier point.¹²

1
NYC Mayor’s Office of Contract Services. Questions and Answers about Local Law 34 and the Doing Business Database
2
American Legal Publishing Corporation. New York City Administrative Code 3-702 – Definitions
3
NYC Department of City Planning. Preparing an Application
4
Mayor’s Office of Contract Services. NYC Doing Business Data Form
5
NYC Mayor’s Office of Contract Services. Doing Business Data Form
6
NYC Mayor’s Office of Contract Services. NYC Doing Business Data Form Instructions
7
Mayor’s Office of Contract Services. LL34 Compliance Quick Guide
8
Mayor’s Office of Contract Services. Doing Business Accountability
9
NYC Mayor’s Office of Contract Services. NYC Doing Business Data Form
10
New York City Campaign Finance Board. Limits and Thresholds
11
New York City Campaign Finance Board. Limits and Thresholds
12
American Legal Publishing Corporation. New York City Administrative Code 3-703 – Eligibility and Other Requirements