
On August 11, 2026, FinCEN issued a final rule permanently eliminating the BOI reporting requirement for U.S. companies and U.S. persons. The rule is effective immediately upon publication in the Federal Register. FinCEN also announced it will delete previously reported BOI belonging to U.S. persons from its database, since that information is no longer required.
This makes permanent what had effectively been the reality since March 2025, when FinCEN suspended enforcement of the requirement against U.S. companies through an interim rule. Foreign entities registered to do business in the U.S. will still need to report beneficial ownership information for their foreign individual owners, but domestic companies and their owners are now fully exempt.
What This Means for You:
– If you haven’t filed a BOI report, you don’t need to.
– If you already filed one, no further action is required, and your previously submitted information for U.S. persons will be removed from FinCEN’s database.
– If you’re a domestic entity with foreign ownership, check with us to confirm whether any reporting obligation still applies.
Our Take:
We were never enthusiastic about this requirement. From the outset, we counseled clients to hold off filing where possible, given how often the deadlines and enforcement posture shifted. During the window when the rule was actively in force, we helped clients who needed to come into compliance, but we viewed the underlying regulation as an overly broad and burdensome imposition on business owners who posed no plausible national security concern. A single-member LLC formed to hold a rental property or a small family business had no business being swept into the same reporting regime designed to combat money laundering and shell-company abuse by bad actors.
This final rule is a win for small business owners. It removes a compliance burden that was disproportionate to the risk it was meant to address, and it does so permanently rather than through another temporary reprieve.
If you have questions about how this affects your business or an entity with foreign ownership, reach out to our office.
