If you own a business, or your trust owns part of one, you may remember being told you had to file a Beneficial Ownership Information report, known as a BOI report, with the federal government under the Corporate Transparency Act. Deadlines moved again and again. Courts suspended the requirement, then brought it back, then suspended it again. Many business owners simply lost track of where things stood.
Here is where it stands now. If your company was formed in the United States, you do not have to file a BOI report. That is now permanent, and there is nothing to file, update, or extend.
On August 11, 2026, the U.S. Treasury's Financial Crimes Enforcement Network (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.
The final rule makes permanent an exemption FinCEN first put in place on a temporary basis in March 2025. Since then, companies created in the United States have no longer been treated as "reporting companies," and the final rule published in the Federal Register locks that in.
In practical terms, if you have an LLC or corporation formed in any U.S. state, you do not need to file an initial BOI report, and you do not need to update or correct one you already filed.
Many careful business owners filed in 2024 or early 2025, when the requirement looked firm. If that was you, there is nothing more you need to do.
FinCEN has announced it will delete information previously reported by U.S. persons from its beneficial ownership database. If you obtained a FinCEN ID, FinCEN's own Q&A confirms you are no longer required to update or correct the information you gave when you applied for it.
Earlier guidance, including articles we published in 2023, explained that if your trust owned part of a small business, the trustee or beneficiaries of that trust might have to be reported to FinCEN. That is no longer the case for U.S. companies and U.S. persons.
If your trust holds an interest in a family business, rental LLC, or other company formed in the United States, there is no BOI report to file, and no need to report your trustee or beneficiaries to FinCEN. The privacy your trust provides is not affected by the Corporate Transparency Act.
The requirement has not disappeared entirely. According to FinCEN, it now applies only to companies formed under the law of a foreign country that have registered to do business in a U.S. state. Even those companies do not have to report information about U.S. persons who own or control them.
If you have a business entity formed outside the United States and registered to do business here, talk with your attorney about whether it must file.
New York has its own law, the LLC Transparency Act, which took effect January 1, 2026. Under the New York Department of State's guidance, it currently applies only to LLCs formed under the law of a foreign country and authorized to do business in New York. LLCs formed in the United States are not required to report under it.
All of the confusion around BOI reporting created an opening for fraud. Business owners have received letters and emails demanding a "filing fee," referencing forms such as a "Form 4022" or "Form 5102," or threatening penalties.
FinCEN has warned that it does not ask for payment by phone, mail, or website, and it does not have those forms. If you receive a message like this about your U.S. company, do not respond, click any link, or send money. There is nothing to file.
The end of BOI reporting does not mean ownership records stop mattering. Banks still ask who owns and controls a business when you open an account, because they have their own beneficial ownership requirements under a separate federal rule. And the people who will need to know who owns your business most are not in Washington. They are your family.
If something happened to you tomorrow, would your family know which entities you own, how they are held, and who has the authority to step in? Is your business interest owned by your trust, or still in your individual name, where it may have to go through court? Does your operating agreement say what happens when an owner dies or becomes incapacitated?
Those questions matter far more to your family than any government report ever did. If you are a business owner, you can read more about why estate planning is so essential for business owners and why business owners deserve more than an easy or cheap estate plan.
The Corporate Transparency Act itself is still a federal law. What changed is how FinCEN applies it. Rules can change again, so if you hear something new, check FinCEN's beneficial ownership page directly before acting on it, and talk with your attorney.
A Personal Family Lawyer® firm can review how your business is owned, make sure it is coordinated with your trust and the rest of your plan, and help your family know exactly what to do if something happens to you.
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