Corporate Transparency Act BOI reporting: do you still need to file in 2026?
Updated April 2026
If you've been stressing about Beneficial Ownership Information reporting for your LLC, there's a good chance you can stop. The rules changed significantly in March 2025, and most small business owners in the United States are now exempt from filing. But the confusion around this topic is enormous — partly because the rules changed multiple times in rapid succession, and partly because much of the information still circulating online reflects the old requirements.
Here's the current state of affairs, in plain language.
What happened with BOI reporting
The Corporate Transparency Act was enacted in 2021 with the goal of preventing money laundering, tax fraud, and terrorist financing by requiring businesses to disclose their beneficial owners to FinCEN (the Financial Crimes Enforcement Network, a bureau of the US Treasury Department). The original rule required most LLCs and corporations formed in the United States to file a BOI report identifying everyone who owns or controls 25% or more of the company, or who exercises substantial control over it.
This created a massive compliance burden. An estimated 32 million businesses were expected to file, most of them small LLCs and family-owned companies that had nothing to do with the financial crimes the law was designed to prevent.
After multiple legal challenges, court injunctions, and enforcement pauses throughout 2024 and early 2025, the Treasury Department announced in March 2025 that it would narrow the scope of the rule. On March 26, 2025, FinCEN published an interim final rule that changed the game entirely.
The current rule as of 2026
All US-created entities are now exempt from BOI reporting. If your LLC or corporation was formed by filing documents with a secretary of state or similar office in any US state or territory, you are not required to file a BOI report with FinCEN. This includes single-member LLCs, multi-member LLCs, S-Corps, C-Corps, and any other entity type formed domestically.
The rule now applies only to foreign companies. The only entities still required to file BOI reports are those formed under the law of a foreign country that have registered to do business in a US state or tribal jurisdiction. These foreign reporting companies must file within 30 days of their US registration becoming effective.
US persons are exempt from being reported. Even for foreign companies that must file, US citizens and residents do not need to be reported as beneficial owners. Only non-US beneficial owners and company applicants must be disclosed.
What this means for your small business
If you formed your LLC or corporation in any US state — which describes the vast majority of small businesses reading this — you have no BOI reporting obligation to FinCEN. You don't need to file an initial report, you don't need to file updates, and you don't need to worry about the penalties that were originally attached to non-filing.
This is a significant relief for small business owners, but it comes with an important caveat: the interim final rule is exactly that — interim. FinCEN has indicated it intends to finalize the rule, and there's always a possibility that future regulatory changes could expand the scope again. For now, however, the exemption for domestic companies is in effect and the Treasury Department has explicitly stated it will not enforce penalties against US companies or US persons.
Why this doesn't eliminate your compliance obligations
The BOI exemption is good news, but it only removes one item from your compliance checklist. Your LLC still has every other obligation it had before — annual reports (or biennial reports, depending on your state), state tax registrations and filings, registered agent maintenance, business license renewals, employer tax requirements if you have employees, and any state-specific requirements like franchise taxes, privilege taxes, or entity-level taxes.
These state-level obligations haven't changed at all. They're still enforced, they still have deadlines, and they still carry penalties for non-compliance. In fact, the attention many business owners gave to BOI reporting over the past two years may have distracted them from their ongoing state compliance requirements — creating a catch-up problem that's more immediately dangerous than BOI ever was.
Stay on top of what actually matters
The filing that will get your LLC dissolved isn't a federal BOI report — it's your state annual report. The penalty that will cost you hundreds or thousands of dollars isn't from FinCEN — it's from your Secretary of State or Department of Revenue. The compliance obligations that protect your liability shield aren't federal transparency requirements — they're the state-level filings that keep your entity in good standing.
Our state-specific compliance guides cover every one of these obligations — all the filings, deadlines, fees, and penalties that actually apply to your business right now in your state. No guesswork, no outdated information, no confusion about what's been repealed and what hasn't.
Find your state's complete compliance guide here — 27 pages of everything your LLC needs to stay in good standing, for $37.