What BOI reporting is
The Corporate Transparency Act (CTA) created a requirement for companies to report their beneficial owners, the humans who ultimately own or control them, to FinCEN, the US Treasury's financial crimes unit. The goal: ending anonymous shell companies. The report itself is simple, names, birthdates, addresses, ID documents of owners, filed electronically with FinCEN, not public.
The short, chaotic history
- Jan 2024: BOI reporting goes live. Every US LLC and corporation ("reporting companies") must file; penalties quoted at up to $500+/day.
- Late 2024: federal courts issue injunctions; deadlines whipsaw on and off within weeks.
- March 2025: FinCEN issues an interim final rule that removes the requirement for US-formed ("domestic") companies entirely. Only foreign companies registered to do business in the US remain in scope, and even they don't report US-person beneficial owners.
Where the rule stands now
| Entity | BOI filing required? |
|---|---|
| Wyoming/Delaware LLC formed in the US, owned by non-US residents | No, domestic companies are exempt under the 2025 interim rule |
| non-US company registered as a foreign entity doing business in a US state | Yes, foreign reporting companies remain in scope |
Read that first row again, because it contradicts hundreds of formation-mill blog posts and even some current sales pitches: your US-formed LLC does not currently owe a BOI report, regardless of your citizenship. The requirement attaching to formation in the US was lifted; what matters now is where the entity was formed, not who owns it.
What this means for your LLC
- If you never filed: as of mid-2026, you're not delinquent, there's nothing due for a domestic LLC.
- If you filed in 2024: no harm; the data sits with FinCEN, and no updates are currently owed by exempt companies.
- If someone quotes you "$500/day BOI penalties" today to sell a filing service for a US-formed LLC, they're running on stale information, a useful signal about the rest of their advice, too.
Why you should still watch this space
The interim rule was controversial, it substantially narrowed a statute Congress passed, and litigation plus political shifts could revive broader requirements with new deadlines. This is exactly the kind of rule that changes back with a 90-day compliance window and zero fanfare. Our approach: we track it, and if BOI obligations return for domestic LLCs, filing is handled as part of keeping clients in good standing, it's in the compliance calendar as a monitored item, not a forgotten one.
📌Status line
As of July 2026: US-formed LLCs, no BOI filing due. Foreign-registered entities, still in scope. We update this page when the rule moves.
