Updated October 3, 2026
U.S. companies are no longer required to file beneficial ownership information reports with the Financial Crimes Enforcement Network under the Corporate Transparency Act.
FinCEN issued a final rule in August 2026 that made permanent the reporting exemptions first introduced in March 2025. The final rule became effective on August 14, 2026.
Under the current rule:
Companies created in the United States are exempt from federal BOI reporting.
U.S. persons do not have to provide BOI to a reporting company.
A reporting company does not have to report a U.S. person's information as a beneficial owner or company applicant.
A U.S. person with a FinCEN identifier does not have to update or correct information previously submitted to FinCEN.
This is a substantial change from the rules that applied when the CTA reporting system first launched in 2024.
Which entities may still have to report?
The current definition of a reporting company is generally limited to an entity formed under the law of a foreign country that registers to do business in a U.S. state or Tribal jurisdiction by filing a document with a secretary of state or similar office.
A foreign entity that falls within that definition must still determine whether one of the regulatory exemptions applies. If it remains a reporting company, it generally must report information about the entity and its non-U.S. beneficial owners and company applicants. It does not report U.S. persons in those roles.
FinCEN states that:
A covered foreign entity registered to do business in the United States before March 26, 2025, was required to file by April 25, 2025.
A covered foreign entity registered on or after March 26, 2025, generally has 30 calendar days after receiving notice that its registration is effective to file its initial report.
Foreign entities should review the current rule and FinCEN guidance rather than rely on summaries prepared before March 2025.
What should a U.S. startup do now?
A corporation or limited liability company created under U.S. law does not need to file a BOI report under the current federal rule. Its U.S. founders, officers, directors, and owners also do not have to provide BOI for CTA reporting.
Companies should still keep ordinary formation, ownership, capitalization, tax, licensing, and state-registration records current. A BOI exemption does not eliminate other federal or state disclosure, tax, banking, licensing, or regulatory obligations.
If a company previously filed a BOI report, its U.S. persons are not required to update or correct the information they submitted to FinCEN. A foreign reporting company may still have an update or correction obligation for reportable non-U.S. information.
Watch for BOI filing scams
FinCEN warns that fraudulent notices may request payment, cite fake forms, use suspicious links or QR codes, or claim to come from a nonexistent agency. There is no fee to file directly with FinCEN. Verify any request through FinCEN's official website before providing personal or company information.
Official resources
The rules may apply differently to a foreign entity, a regulated business, or a company with non-U.S. owners or operations. Review the current rule and the specific facts before deciding that no filing is required.
Frequently asked questions
Must a U.S. company file a BOI report?
No. Under the current FinCEN rule, companies created in the United States are exempt from federal beneficial ownership information reporting.
Which entities may still need to file?
Certain entities formed under foreign law and registered to do business in a U.S. state or Tribal jurisdiction may still have to report unless a regulatory exemption applies.
Do U.S. persons have to provide BOI?
No. Under the current rule, U.S. persons do not have to provide beneficial ownership information to a reporting company, and reporting companies do not report U.S. persons in covered roles.
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