The Financial Crimes Enforcement Network (FinCEN) has issued a final rule removing the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) under the Corporate Transparency Act. The rule took effect on August 14, 2026, and finalizes the rollback that began with the agency’s interim rule in March 2025. FinCEN describes the change as permanent. If your company was formed in the United States, you have nothing left to file with FinCEN and nothing to withdraw.
The harder question is what didn’t change. Beneficial ownership requirements are still in force in a handful of states and at your bank, and because they share a name with the federal rule that just ended, they are easy to overlook.
Who Is Still Required to File?
Only foreign reporting companies still file. The rule narrows “reporting company” to a single category: entities formed under the law of a foreign country that have registered to do business in a U.S. state or Tribal jurisdiction by filing a document with a secretary of state or similar office.
Those companies file, but they report considerably less than before:
- U.S. person beneficial owners are excluded. A foreign reporting company reports only its foreign individual owners.
- U.S. person company applicants are excluded. This is new in the final rule. The March 2025 interim rule still required foreign entities to report U.S. person company applicants.
- Foreign pooled investment vehicles registered in the United States no longer report a U.S. person who controls the vehicle.
The existing exemption categories continue to apply to foreign entities, so registering in a U.S. state does not by itself create a filing obligation. Foreign-formed entities should confirm their status rather than assume it in either direction.
Deadlines for foreign reporting companies are unchanged. An initial report is due within 30 calendar days of notice of registration, and updates or corrections are due within 30 calendar days.
What Happens to Information You Already Filed?
FinCEN will delete beneficial ownership information previously reported by U.S. persons, working with the National Archives and Records Administration. Three details are worth knowing:
- The deletion covers individuals, not companies. It reaches information about beneficial owners, company applicants, and recipients of a FinCEN ID. FinCEN has not said that company-level details will be removed.
- Filers do not need to request deletion. FinCEN has stated that it does not anticipate asking U.S. companies or persons to contact the agency, and it does not intend to confirm deletion to individual filers. It will post notice on FinCEN.gov once the process is finished.
- The deletion has a cutoff date. FinCEN intends to run the process once rather than on a recurring basis. If information about a U.S. company or U.S. person appears in a filing made after February 10, 2027, FinCEN does not anticipate deleting it.
FinCEN has not announced when the deletion will be complete.
Do You Still Need to Update a FinCEN ID?
If you are a U.S. person, you do not need to update a FinCEN ID. The final rule removes the obligation for U.S. persons to update or correct the information they originally submitted to obtain a FinCEN identifier.
Two exceptions remain. Individuals who are not U.S. persons must still report changes within 30 calendar days and correct inaccuracies within 30 days of becoming aware of them. Separately, a reporting company that holds a FinCEN identifier must keep the company’s own information current by filing an updated or corrected BOI report.
Why Is Your Bank Still Asking About Beneficial Owners?
Banks and other covered financial institutions must still collect beneficial ownership information from legal entity customers under FinCEN’s Customer Due Diligence (CDD) Rule, which the final rule did not change. That obligation is set out in a separate regulation and applies to the financial institution rather than to your company.
If you open an account after reading that BOI reporting has ended and the bank still asks for beneficial ownership details, nothing has gone wrong. These are two different requirements that happen to share a name.
Which State Requirements Still Apply?
Federal relief does not extend to the states, and three jurisdictions have requirements on the books today.
New York. The LLC Transparency Act took effect January 1, 2026. Because the statute cross-references the federal definition of a reporting company, the federal narrowing carried over into the state law, and a decoupling bill that would have restored the original scope was vetoed in December 2025. New York’s requirement now reaches only LLCs formed under the law of a foreign country that are authorized to do business in New York. LLCs formed in New York or in any other U.S. state are exempt. Covered LLCs authorized before January 1, 2026 have until January 1, 2027 to file their initial disclosure. Covered LLCs also owe an annual confirmation, and penalties can reach $500 per day.
District of Columbia. The District has required beneficial ownership disclosure since 2020, and it operates independently of the federal rule. Entities report through registration filings and the biennial report rather than a separate filing. The threshold is lower than the federal one: disclosure is required for anyone holding more than 10% of a governance or distributional interest, and for anyone below that threshold who controls the entity’s financial or operational decisions or directs its day-to-day operations. See the DLCP guidance for details.
South Dakota. Under SD Statute § 59-11-24, entities that own agricultural land in South Dakota must disclose whether they have foreign beneficial owners.
Other states continue to consider their own requirements. Massachusetts is among the most active. For a fuller breakdown of how the state requirements compare, see our overview of state-level BOI requirements.
What This Means for Your Organization
For the overwhelming majority of U.S. businesses and nonprofits, this is straightforward relief and no action is required. There is nothing to file, nothing to withdraw, and no request to submit.
Three groups should look more closely: organizations with foreign-formed entities registered in the United States, organizations operating in New York, the District of Columbia, or South Dakota, and multi-entity groups where it is not obvious at a glance which entities were formed where. That last group is where errors tend to surface, less because the rule is complicated than because the entity list is long.
How Harbor Compliance Can Help
Requirements that disappear at the federal level have a way of reappearing at the state level, and tracking which entity owes what is the kind of work that quietly consumes a compliance team’s week. Our BOI Reporting Service handles the filings that remain and monitors emerging state-level requirements, and our software gives you a single view of your entities and their obligations in every jurisdiction where you operate. Contact us today to learn how Harbor Compliance can help.
