- 18 Nov 2026 UK Have your directors and PSCs verified with Companies House?
- 1 Dec 2026 AU Will your onboarding accept private-sector Digital IDs?
- 10 Dec 2026 AU Does your privacy policy explain your automated KYC decisions?
- End 2026 EU Is your ID verification ready for EUDI Wallets?
- 1 Jan 2027 US Can your age checks keep up state by state?
- 1 Apr 2027 JP Is your eKYC ready for the IC-chip mandate?
- 10 Jul 2027 EU Is your CDD flow ready for the AMLR?
- 1 Jan 2028 US Are your adviser clients ready for FinCEN’s AML rule?
- 31 Mar 2029 AU Is your initial CDD on the new AUSTRAC model?
- Now AU Tranche 2 is live. Is your AML/CTF program running?
BOI reporting: who still files under the Corporate Transparency Act
FinCEN's final rule, effective 14 August 2026, permanently removes US companies and US persons from beneficial ownership information (BOI) reporting. Only foreign companies registered to do business in the US still file.
- BOI reporting is no longer required for any company created in the United States. FinCEN's final rule, issued 11 August 2026 and effective 14 August 2026, made that exemption permanent.
- A reporting company is now only an entity formed under foreign law that has registered to do business in a US state or tribal jurisdiction, unless an exemption applies.
- Foreign reporting companies report their foreign beneficial owners only. They do not report US persons, and they file within 30 calendar days of notice that their US registration is effective.
- FinCEN says it will delete information previously reported by US persons from its beneficial ownership database.
What it is
The Corporate Transparency Act set up a federal register of the people who own or control companies. From 1 January 2024 most small US companies had to file a beneficial ownership information report with FinCEN. That changed in 2025. On 21 March 2025 FinCEN announced an interim final rule, published on 26 March 2025, that exempted every entity created in the US and narrowed "reporting company" to foreign entities registered to do business in the US.
On 11 August 2026 FinCEN issued the final rule that makes the exemption for US companies and US persons permanent. FinCEN's BOI page gives the effective date as 14 August 2026. Foreign reporting companies remain in scope and still report beneficial ownership information for foreign individuals.
For firms that onboard company clients, the practical result is simple. A US-formed company has no FinCEN BOI filing to show you, so the beneficial ownership picture comes from what you collect and check yourself. See what a beneficial owner is.
Who it applies to
BOI reporting now applies to a narrow group. A company has to report only if all of these are true:
- It was formed under the law of a foreign country.
- It has registered to do business in a US state or tribal jurisdiction by filing with a secretary of state or similar office.
- It does not qualify for one of the reporting exemptions.
Even then, the company leaves out any beneficial owner or company applicant who is a US person. US citizens, domestic companies and their beneficial owners face no BOI penalties, according to FinCEN. Accountants, lawyers and formation agents are affected only where they file on behalf of foreign client companies.
What you have to do
These duties sit with the foreign reporting company. Firms that file for clients do the work on the client's behalf. US companies have nothing to file.
- Confirm whether the company must report
Check that the entity is foreign-formed, registered to do business in a US state, and not exempt. A US-formed entity is exempt.
One-off - Identify the foreign beneficial owners
A beneficial owner is an individual who exercises substantial control over the company or owns or controls at least 25% of its ownership interests, directly or indirectly. Leave out US persons.
- Collect each owner's identifying details
For each reported beneficial owner: name, date of birth, residential address, an identifying number from an acceptable ID document with its issuing jurisdiction, and an image of that document.
- File the initial report
File through the BOI E-Filing System within 30 calendar days of notice that the US registration is effective. FinCEN charges no fee.
Filed with FinCEN - Update or correct the report
File an updated report no later than 30 days after a change, and a corrected report no later than 30 days after the company becomes aware of an inaccuracy.
Ongoing
What firms get wrong
BOI coverage changed three times in two years, and many pages still describe the 2024 regime.
Not since March 2025. FinCEN's final rule effective 14 August 2026 permanently exempts all entities created in the US and all US persons.
Foreign entities registered to do business in the US are still reporting companies unless exempt. FinCEN's FAQs say they must report BOI for their foreign beneficial owners.
US companies no longer file, and FinCEN says it will delete information previously reported by US persons. Firms that need ownership information have to collect it from the client under their own program.
What happens when
- In force
FinCEN announces the interim final rule exempting US companies and US persons Source
- In force
Interim final rule published in the Federal Register; reporting company narrowed to registered foreign entities Source
- In force
FinCEN issues the final rule permanently ending BOI reporting for US companies and US persons Source
- In force
Final rule takes effect Source
Related guides
Questions people ask
Is BOI reporting still required?
Not for US companies or US persons. FinCEN's final rule, effective 14 August 2026, permanently exempts them. Foreign companies registered to do business in a US state still report unless an exemption applies.
What is the BOI reporting deadline for a foreign company?
30 calendar days after the company receives notice that its US registration is effective. Updates and corrections are due within 30 days of the change or of becoming aware of the error.
What does a BOI report include?
The company's legal name and trade names, US address, jurisdiction of formation or registration and tax identification number. For each foreign beneficial owner: name, date of birth, residential address, an ID number and an image of the ID document.
What are the penalties for not filing?
FinCEN's FAQs list civil penalties of up to $500 for each day a wilful violation continues, adjusted for inflation, and criminal penalties of up to two years in prison and a fine of up to $10,000. FinCEN says it will not enforce penalties against US citizens or domestic companies.
Does this change how firms check the owners of US company clients?
It removes a register you might have asked a client to produce. Under your own AML program you still decide how to identify and verify owners. See the customer due diligence checklist.
Primary sources
Checked 5 Nov 2026. We review this page every 90 days and when the rules change.
- FinCEN, Beneficial Ownership Information Reporting
- FinCEN, FinCEN Permanently Ends Beneficial Ownership Reporting Requirements for Millions (11 Aug 2026)
- FinCEN, FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons (21 Mar 2025)
- FinCEN, Beneficial Ownership Information FAQs
Where StackGo fits
StackGo is compliance middleware. IdentityCheck does not file anything with FinCEN. It suits firms that collect and check the people behind company clients under their own policies, which matters more now that US companies have no BOI filing to show.
- Multi-entity onboarding forms that collect each person and entity on a client's structure.
- Biometric identity verification: a photo of a government ID document plus a live selfie with liveness, covering 12,500 document types from 230+ countries and territories.
- PEP, sanctions and adverse media screening of owners and controllers, with ongoing monitoring.
- It does not prepare or file BOI reports, or any other report, with FinCEN.
- Credit bureau beneficial ownership reports are an Australian add-on only and do not cover US entities.
- No legal advice on whether a company is a reporting company or exempt.
Ready to make onboarding minutes, not hours?
Start free and run your first check today, or book a demo and we will walk you through it.