BOI Reporting Is Permanently Gone for US-Formed Companies

Do you still need to file a BOI report?

If your business was formed in the United States, no. FinCEN issued a final rule that took effect August 14, 2026, permanently eliminating beneficial ownership information reporting under the Corporate Transparency Act for US-formed companies and US-person beneficial owners. If you’ve been putting off a filing, waiting for the lawsuits to settle, or just confused about where this landed, that confusion is over: there’s nothing to file.

Why has this been so confusing?

The Corporate Transparency Act originally set a January 1, 2024 reporting deadline for basically every LLC and corporation in the country, then got tangled in a string of federal court injunctions, a brief reinstatement, and a lot of whiplash headlines through 2024 and early 2025. FinCEN tried to settle things down with an interim final rule on March 26, 2025, which narrowed the requirement to foreign-formed companies only and excused domestic companies and US persons from filing while that rule was finalized. The August 2026 rule makes that narrowing permanent rather than provisional.

Who still has to file?

Foreign reporting companies, meaning entities formed outside the US but registered to do business here, still have reporting obligations. The twist is they only have to report their non-US-person beneficial owners and company applicants; a foreign company’s US-person owners don’t need to be reported. FinCEN estimates roughly 28,000 foreign entities fall into this category, and about 13,000 of them had already filed by the end of 2025.

If you’re a California merchant who formed your LLC or corporation here and your owners are US persons, this entire section doesn’t apply to you.

What happens to the information you already filed?

FinCEN is deleting previously submitted BOI data on US persons from its database, and US persons no longer need to update or correct information tied to a FinCEN identifier they obtained earlier. You don’t owe FinCEN anything further on this.

Two things this doesn’t change

This rule is specifically about the federal Corporate Transparency Act reporting requirement, and it doesn’t touch two other things business owners sometimes confuse with it. First, if your bank asked for beneficial ownership information when you opened a business account, that’s a separate customer due diligence requirement banks have always had, and it’s unaffected. Second, some states are building their own beneficial ownership reporting rules, New York’s LLC Transparency Act being the most prominent example, so check whether your state has its own requirement rather than assuming federal relief covers everything.

The bottom line

For a US-formed LLC or corporation with US-person owners, the federal BOI reporting requirement is dead, not paused. You don’t need to file, update, or watch for another deadline on this one. Keep the FinCEN final rule and its effective date somewhere handy in case your accountant or attorney asks, but there’s no action for you to take.

This is general information, not legal advice. If you’re not sure whether your business counts as a domestic or foreign reporting company, or whether a state-level reporting law applies to you, talk to your attorney or accountant.

Sources: Steptoe, Haynes Boone, Greenberg Traurig, and Troutman client alerts on the FinCEN final rule.