BOI Reporting Is Officially Dead for U.S. Companies
FinCEN ends the BOI reporting requirement for U.S. companies under the Corporate Transparency Act; foreign entities still must file.
FinCEN has backed away from its much-debated beneficial ownership information (BOI) reporting requirement for U.S. companies under the Corporate Transparency Act (CTA).
After months of confusion and a lot of back and forth from the courts and regulators, FinCEN issued an interim final rule that exempts all U.S. companies and their beneficial owners from this reporting obligation. Only foreign entities registered in the United States now will be required to submit BOI reports. Foreign entities, however, will not be required to report any U.S. persons as beneficial owners, and U.S. persons will not be required to report BOI with respect to any foreign entity for which they are a beneficial owner.
If you're a U.S. company or U.S. beneficial owner, you can finally exhale. But foreign entities registered to do business in the United States still must file.
For those interested in FinCEN's official words, find them here.
As of mid-2026, the exemption for U.S. companies remains in effect. FinCEN's rule is still technically an interim one, with a final rule pending, so the requirement could be revisited. We will update clients if anything changes.
DISCLAIMER: This article is for informational purposes only and does not constitute legal advice. The information provided is based on current understanding as of the date of publication. Legal outcomes can change rapidly, and individual circumstances may vary. Please consult a qualified attorney for advice specific to your situation.