On August 11, 2026, the Financial Crimes Enforcement Network (“FinCEN”) issued a final rule permanently exempting U.S. companies and U.S. persons from Beneficial Ownership Information (“BOI”) reporting requirements under the Corporate Transparency Act (“CTA”). The final rule adopts and makes permanent the exemptions first introduced in FinCEN’s March 2025 Interim Final Rule, referenced in our previous alert here.
Under the final rule:
- Domestic reporting companies, meaning entities formed in the United States, are no longer required to file BOI reports with FinCEN.
- U.S. persons are exempt from BOI reporting obligations and are no longer required to update or correct information previously provided to obtain a FinCEN identifier (“FinCEN ID”).
- Foreign reporting companies remain subject to BOI reporting requirements but generally must report only foreign beneficial owners.
- FinCEN announced that it will delete BOI information previously reported by U.S. persons and other individuals it reasonably determines are U.S. persons.
The final rule brings long-awaited certainty to businesses that have been navigating the CTA’s reporting requirements amid extensive litigation, regulatory changes and Treasury Department announcements over the past few years. With the rule now finalized, U.S. companies and U.S. individuals no longer have any obligation to file BOI reports under the CTA.
Although the CTA’s reporting framework remains in place for certain foreign entities doing business in the United States, the final rule significantly narrows the statute’s scope and permanently removes reporting obligations for domestic entities and U.S. persons who are beneficial owners.
If you have questions regarding the CTA, BOI reporting requirements, or how these developments may affect your business, please contact attorneys Charmaine Nyman, Dan Desmond, Anthony Austin or any member of Barley Snyder’s Business Practice Group.
