Is BOI Reporting Still Required? Here’s What Changed

Key Takeaways

• The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a final rule on August 11, 2026, permanently ending beneficial ownership information (BOI) reporting requirements for U.S. companies and U.S. persons under the Corporate Transparency Act (CTA).
• The rule took effect August 14, 2026, and makes permanent the exemptions first introduced in March 2025.
• FinCEN will delete previously submitted BOI data belonging to U.S. persons from its database.
• Foreign companies registered to do business in the United States must still report BOI for their foreign owners, though some related obligations have been narrowed.

For years, business owners have been asking the same question on repeat: do I actually have to file a beneficial ownership report?

Between court injunctions, delayed deadlines and shifting guidance from Washington, the honest answer kept changing. A final rule from the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has now put the question to rest for most U.S. businesses, permanently.

Here’s what the new rule says, how we got here and what it means for you going forward.

Is BOI Reporting Still Required?

No, not for most U.S. businesses. On August 11, 2026, FinCEN issued a final rule permanently removing the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act (CTA). BOI refers to information about the individuals who ultimately own or control a business. The rule took effect August 14, 2026.

FinCEN also announced it will delete beneficial ownership information already submitted by U.S. persons now that they are exempt from the requirement.

How We Got Here: A Timeline of Corporate Transparency Act Reporting

The CTA’s BOI reporting requirements took effect in January 2024, and the time since has brought a steady stream of court rulings, injunctions and delayed deadlines.

The most significant turn came in March 2025, when Treasury issued an interim final rule exempting nearly all U.S. companies and individuals from reporting, limiting the requirement to foreign entities registered to do business in the United States. This most recent rule makes that exemption permanent.

What FinCEN’s Final Rule Actually Changes

The final rule:

• Makes permanent the exemptions for U.S. companies and U.S. persons introduced in the March 2025 interim rule.
• Exempts U.S. persons who already obtained a FinCEN ID from any obligation to update or correct that information going forward.
• Removes the requirement for foreign companies to report the U.S. persons who helped them register to do business in the United States.
• Exempts foreign pooled investment vehicles registered in the United States from reporting BOI for a U.S. person who controls the vehicle.
• Confirms FinCEN will delete information about any individual it reasonably believes is a U.S. person, including data tied to a U.S. passport or driver’s license.

Foreign entities that qualify as reporting companies still must report BOI for their foreign individual owners.

What This Means for Your Business

If your business already filed a BOI report, you do not need to take any action. FinCEN will handle the deletion of that data on its own timeline. If you had a report pending or were waiting to see how this played out before filing, you no longer need to.

Treasury Secretary Scott Bessent framed the rule as regulatory relief for what he called a burdensome requirement on law-abiding business owners. Not everyone agrees. Financial transparency advocates argue the rollback weakens tools meant to fight money laundering and other financial crimes. Whatever side of that debate you fall on, the practical result for most U.S. businesses is the same: the reporting obligation is gone, and it isn’t coming back without new legislation or another shift in Treasury’s approach.

Contact your attorney or legal advisor if you have questions about how this final rule affects your business or any remaining compliance considerations.

FAQ

Do I need to file a BOI report if I haven’t already?

No. U.S. companies and U.S. persons are now permanently exempt from filing beneficial ownership information reports under the CTA.

I already filed a BOI report. What happens to that information?

FinCEN has stated it will delete previously submitted BOI data for individuals it reasonably believes are U.S. persons. You do not need to request this yourself.

Does this rule apply to foreign-owned businesses?

Not entirely. Foreign entities registered to do business in the United States must still report beneficial ownership information for their foreign individual owners, though some related obligations, like reporting U.S. persons who helped with registration, have been removed.

Could this requirement come back?

It’s possible. Some advocacy groups have pushed for Congress to repeal the CTA outright, while others have challenged the rollback in court. Barring new legislation or further litigation, this final rule is the current state of the law.

About the Author

Jonathan Levens, CPA, is a Partner in Moore Colson’s Tax Practice Area focusing on tax compliance and advisory services for closely-held businesses, their owners, private equity and venture capital. He has extensive experience in merger and acquisition structuring and due diligence services.