No More Beneficial Ownership Reporting: FinCEN Makes the Exemption Permanent for U.S. Companies
As of August 11, 2026, U.S. Treasury Financial Crimes Enforcement Network (“FinCEN”) permanently ended beneficial ownership reporting requirements for U.S. companies. FinCEN has issued a final rule that permanently eliminates the federal beneficial ownership information (BOI) reporting requirement for U.S. companies and U.S. persons under the Corporate Transparency Act.
Under the final rule, U.S.-formed companies are no longer required to report BOI to FinCEN; U.S. persons are no longer required to report BOI under the CTA and FinCEN will delete previously reported BOI submitted by U.S. persons who are now exempt from the reporting requirements.
However, foreign entities registered to do business in the United States remain subject to BOI reporting requirements, but only with respect to applicable foreign individuals.
The rule is effective upon publication in the Federal Register.
What This Means for Small Businesses
For most small businesses formed in the United States, the federal BOI reporting obligation under the Corporate Transparency Act is now no longer applicable. This represents a significant change from the CTA’s original reporting framework and eliminates an ongoing federal compliance obligation for millions of U.S. businesses. Businesses with foreign ownership or foreign-formed entities registered to conduct business in the United States should continue to evaluate their BOI reporting obligations, as the final rule does not eliminate those requirements.
As always, businesses should consider their specific ownership and entity structure before concluding that no BOI filing is required. Our business law team is continuing to monitor the implementation of the final rule and its impact on U.S. and foreign entities.