UPDATE: FinCEN issued a final rule on August 11, 2026 that took effect on August 14, 2026. The rollback described in this article is no longer temporary; it is now permanent. FinCEN has also announced it will delete beneficial ownership information previously submitted by U.S. persons. The sections below have been updated to reflect the final rule.
The BOI Rollback Is Now Permanent
For more than a year, the exemption that freed most U.S. business owners from BOI reporting rested on an interim rule, a temporary measure that FinCEN could have revised, and that many observers expected Congress to settle one way or the other.
That question is now answered. On August 11, 2026, FinCEN issued a final rule that permanently removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information under the Corporate Transparency Act. The rule took effect on August 14, 2026, upon publication in the Federal Register.
If your business was formed by filing paperwork with a U.S. state (an LLC, corporation, S corp, LP, or LLP), you have no federal BOI filing obligation. Not an initial report, not an update, not a correction. That is now settled regulation rather than a temporary posture.
What the Final Rule Changed from the Interim Rule
The final rule adopts everything the March 2025 interim rule did and makes it permanent. It also adds two pieces of relief that go further than the interim rule did:
- Foreign companies no longer report U.S. company applicants. If a U.S.-based person helped a foreign company register to do business in the United States, that person’s information is no longer reportable.
- U.S. persons holding a FinCEN ID don’t have to maintain it. If you obtained a FinCEN identifier and your address, name, or ID document has since changed, you are not required to update or correct what you submitted.
Everything else carries forward: U.S. companies are exempt, U.S. persons are exempt from providing their information to any reporting company, and only certain foreign-formed entities remain in scope.
Will FinCEN Delete the BOI You Already Filed?
This is the question we’re hearing most, and it deserves a precise answer rather than a reassuring one.
FinCEN has said it will delete this information but has not said when.
Here is exactly what the agency has committed to. FinCEN is implementing a process to delete information about any individual (beneficial owner, company applicant, or FinCEN ID holder), that the agency reasonably believes was provided by a U.S. person. It will identify those records using the documentation attached to them, such as a U.S. passport or a U.S. driver’s license. FinCEN has also said it expects to coordinate with the National Archives and Records Administration to make sure the deletion complies with federal records laws.
What FinCEN has not published is a completion date, a progress milestone, or a way to check the status of a specific filing.
What this means for you, practically:
- There is nothing to submit. FinCEN has not created a deletion request form, and there is no action required on your part to be included. The process is one FinCEN runs on its own records.
- You don’t need to correct old filings first. If information you submitted was outdated or wrong, you are not required to fix it before deletion. U.S. persons have no update or correction obligation.
- Expect this to take time. Coordinating a purge of this size with federal records law is not a same-week exercise. Treat any promise of immediate removal with skepticism.
- Deletion covers FinCEN’s database only. It does not reach beneficial ownership information you have given elsewhere.
That last point is the one that surprises people, so it’s worth expanding.
Why Your Bank May Still Ask Who Owns Your Company
The final rule ends BOI reporting to FinCEN. It does not touch the separate Customer Due Diligence rule, which requires banks and other covered financial institutions to collect beneficial ownership information from their business customers when accounts are opened.
That obligation is still fully in force, and FinCEN specifically pointed to it as one reason it was comfortable exempting domestic companies. So if your bank asks for ownership details when you open a business account or renew a loan, that request is legitimate and unrelated to the CTA rollback. You still need to answer it.
Who Still Has to File
The reporting requirement now applies to a narrow group: entities formed under the law of a foreign country that have registered to do business in a U.S. state or tribal jurisdiction by filing with a secretary of state or similar office. Several exemption categories still apply on top of that, so a foreign entity should confirm its status rather than assume it must file.
A foreign reporting company that is in scope reports its legal name, any trade or DBA names, its U.S. principal place of business address (or the U.S. address from which it operates), its foreign jurisdiction of formation, the state or tribal jurisdiction where it first registered, and its taxpayer identification number.
It does not report any U.S. person, not as a beneficial owner, and not as a company applicant. Only non-U.S. beneficial owners are reportable.
Has the Corporate Transparency Act Been Repealed?
No, and the distinction matters.
The Corporate Transparency Act remains on the books as federal law. What changed is the regulation implementing it: FinCEN narrowed the definition of “reporting company” through rulemaking, which is a different mechanism than Congress repealing the statute.
In practical terms, the relief is durable. A final rule carries real weight, and reversing it would require a new rulemaking process with its own notice-and-comment period, not an overnight announcement. But because the underlying statute still exists, this remains an area worth checking periodically rather than filing away permanently.
What to Do Now
If your company was formed in the United States: Nothing. No filing, no update, no correction, no deletion request.
If your company was formed outside the United States and registered to do business in a U.S. state: Confirm whether you meet the definition of a reporting company and whether any exemption applies. If you are in scope, only your non-U.S. beneficial owners are reportable.
Everyone: Be skeptical of mail or email demanding a BOI filing fee. Scam notices designed to look like FinCEN correspondence circulated heavily while the rules were in flux, and a rollback this widely misunderstood is exactly the environment where they resurface. FinCEN does not charge a fee to file a BOI report, and most U.S. businesses have nothing to file at all.
Need to File a BOI Report?
CorpNet makes BOI reporting simple! Our business filing experts can take care of all the paperwork for you.
Frequently Asked Questions About BOI Reporting in 2026
Do most small businesses have to file a BOI report in 2026?
No. Under the March 2025 FinCEN rule, businesses formed in the United States are generally exempt. BOI reporting now applies mainly to certain foreign entities registered to do business in the U.S.
Was the Corporate Transparency Act repealed?
No. The CTA has not been repealed and remains on the books as federal law. FinCEN changed how the law is enforced, which is why most domestic companies are currently exempt — but the requirements could change again.
What is a beneficial owner?
A beneficial owner is generally an individual who owns at least 25% of a company or who exercises substantial control over it, as defined under the Corporate Transparency Act.
My company is foreign-formed but registered in the U.S. — do I have to file?
Possibly. Certain foreign entities registered to do business in the United States are still required to file, though some exemptions apply. Review the current rules on FinCEN’s website to confirm your obligation.
