FinCEN Permanently Eliminates BOI Reporting Requirements for US Companies and Persons
August 21, 2026The US Department of the Treasury’s Financial Crimes Enforcement Network has issued a final rule permanently removing beneficial ownership information reporting requirements under the Corporate Transparency Act for US companies and US persons.
On August 11, 2026, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued a press release announcing a final rule permanently eliminating beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) for US companies and US persons.
The final rule will become effective following publication in the Federal Register.
KEY CHANGES UNDER THE FINAL RULE
In addition to making permanent the changes adopted by FinCEN in its March 2025 interim final rule that, among other things, exempted US companies and US persons from BOI reporting requirements under the CTA, the final rule eliminates the requirement for US companies and US persons to report BOI to FinCEN and exempts US persons who have applied for FinCEN identifiers from having to update or correct information previously provided to FinCEN in connection with obtaining those identifiers.
The final rule also maintains the exemption established by the interim final rule for US persons who are beneficial owners of foreign reporting companies. Accordingly, reporting companies are not required to report BOI for their US person beneficial owners or US person company applicants, and US persons are not required to provide BOI to those reporting companies.
FOREIGN REPORTING COMPANIES CONTINUE TO HAVE REPORTING OBLIGATIONS
The final rule does not eliminate BOI reporting requirements for all entities; certain entities that are formed under the laws of a foreign country and registered to do business in the United States must still report BOI for non-US beneficial owners and company applicants.
The final rule also affirms that foreign pooled investment vehicles registered in the United States are not required to provide BOI for a US person in control of the investment vehicle.
PREVIOUSLY SUBMITTED BOI
In connection with the final rule, FinCEN also announced that it is implementing a process to delete from its BOI system previously submitted information about company applicants, beneficial owners, and recipients of FinCEN identifiers that FinCEN reasonably believes was provided by a US person.
FinCEN has not announced a date by which the deletion process will be completed and does not anticipate requiring US companies or US persons to submit requests for the deletion of such information.
LOOKING AHEAD
The final rule permanently eliminates CTA reporting obligations for US companies and US persons, including requirements to file initial, updated, or corrected BOI reports with FinCEN.
Foreign entities registered to do business in the United States should continue to assess whether they qualify as reporting companies and, if so, whether they are still required to abide by BOI reporting requirements pursuant to the CTA.
Contacts
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