BOI rules, orders and deadlines since the Corporate Transparency Act

Do US-formed companies have to file BOI reports now?

No. Domestic entities are excluded from the current federal reporting-company definition. (source)

Company formation and registration—not an owner's nationality—define the reporting-company class described here: Reporting company is limited to a foreign-formed entity registered to do business in a U.S. State or tribal jurisdiction by secretary-of-state/similar filing. (source)

The final rule is 91 FR 52508 — Beneficial Ownership Information Reporting Requirement Revision (final rule) (source), dated August 14, 2026 (source).

Current federal scope: Federal BOI rule effective for foreign reporting companies; U.S. companies and U.S. persons exempt under the 2026 final rule. (source)

What changed, and when: every rule, order and deadline since the Act

The chronology below follows source-bound events that changed the federal BOI framework.

1. January 1, 2021 (source) — Pub. L. 116-283, div. F, title LXIV, § 6403(a) (31 U.S.C. § 5336) (source). Established federal beneficial-ownership reporting to FinCEN. (source)
2. September 30, 2022 (source) — 87 FR 59498 — Beneficial Ownership Information Reporting Requirements (final rule) (source). Set the original BOI reporting rule: who reports, what is reported, and when reports are due. (source)
3. December 22, 2023 (source) — 88 FR 88732 — Beneficial Ownership Information Access and Safeguards (31 CFR 1010.955) (source). Established authorized-access circumstances and safeguards for BOI. (source)
4. February 20, 2024 (source) — 31 CFR 1010.955 — Availability of beneficial ownership information reported under this part (source). Federal national-security, intelligence, or law-enforcement agencies; court-authorized State, local, or Tribal law enforcement; qualifying foreign authorities through a Federal agency; financial institutions for customer due diligence with company consent and qualifying regulators; and Treasury personnel whose duties require access. (source)
5. December 3, 2024 (source) — Texas Top Cop Shop, Inc. v. Garland, No. 4:24-cv-00478 (E.D. Tex.) (source). Preliminarily enjoined federal enforcement of the CTA and stayed the reporting deadlines. (source)
6. December 23 and December 26, 2024 (source) — Texas Top Cop Shop, Inc. v. Garland, No. 24-40792 (5th Cir.) (source). The Fifth Circuit granted a stay pending appeal on December 23, then vacated that stay on December 26. (source)
7. January 23, 2025 (source) — McHenry v. Texas Top Cop Shop, Inc., No. 24A653 (U.S.) (source). Stayed the district court's amended order during the Fifth Circuit appeal and any timely certiorari proceedings. (source)
8. February 18, 2025 (source) — FinCEN Notice FIN-2025-CTA1 (source). BOI reporting resumed, with a general 30-day deadline extension for most companies. (source)
9. March 2, 2025 (source) — Treasury press release SB0038 (source). Treasury suspended CTA BOI-rule enforcement against U.S. citizens and domestic reporting companies and announced a proposed foreign-company-only scope. (source)
10. March 26, 2025 (source) — 90 FR 13688 — Beneficial Ownership Information Reporting Requirement Revision and Deadline Extension (interim final rule) (source). Narrowed BOI reporting to foreign reporting companies and exempted domestic reporting companies. (source)
11. March 26, 2025 (source) — 31 CFR 1010.380(a)(1)(i)-(ii), as amended by 90 FR 13688 (source). Foreign reporting companies existing before March 26, 2025: April 25, 2025; later registrations: 30 calendar days after the earlier of actual or public notice of registration. (source)
12. August 14, 2026 (source) — 91 FR 52508 — Beneficial Ownership Information Reporting Requirement Revision (final rule) (source). Made the narrowed BOI regime permanent and expanded the U.S.-person exemptions. (source)

Not established: present-force status for the enactment and access-requester rows where the source-bound evidence lacks an in-force reference. The appellate stay sequence also carries a provenance gap.

Which companies still report, and by when

The remaining federal reporting-company class is defined here: Reporting company is limited to a foreign-formed entity registered to do business in a U.S. State or tribal jurisdiction by secretary-of-state/similar filing. (source)

The narrowed scope is summarized here: Narrowed BOI reporting to foreign reporting companies and exempted domestic reporting companies. (source)

The earlier deadline has passed. Later registrations follow the notice-linked rule stated here: Foreign reporting companies registered before March 26, 2025 had an April 25, 2025 deadline; later registrations have 30 days after notice/effective registration. (source)

File the report or application as directed here: Federal BOI reports and applications are filed with FinCEN in FinCEN-prescribed form and manner. (source)

An initial report calls for the information listed here: Initial reports collect reporting-company name, trade name, address, jurisdiction, TIN, and beneficial-owner/company-applicant identifying information. (source)

Who can see the BOI already filed with FinCEN?

Access is restricted: BOI reported to FinCEN is confidential except for authorized disclosures in 31 CFR 1010.955. (source)

Established authorized-access circumstances and safeguards for BOI. (source)

The requester classes supported by the cited evidence are: Federal national-security, intelligence, or law-enforcement agencies; court-authorized State, local, or Tribal law enforcement; qualifying foreign authorities through a Federal agency; financial institutions for customer due diligence with company consent and qualifying regulators; and Treasury personnel whose duties require access. (source)

This page does not present that list as exhaustive.

Not established: whether the access rule separately authorizes Treasury access for tax administration.

Not established: whether the rule behind this requester list is currently in force. The brief does not include its in-force evidence reference.

If you are worried about your safety or about who can find your address, confidential help is available. National Domestic Violence Hotline: call 1-800-799-7233 or text START to 88788 (thehotline.org). Safety Net Project, National Network to End Domestic Violence: techsafety.org, including its page on state address confidentiality programs (techsafety.org/address-confidentiality-programs). U.S. Department of Justice Office on Violence Against Women, resources for victims and survivors: justice.gov/ovw/resources-victims-and-survivors. If you are in immediate danger, call 911.

What this means for a US-formed LLC and its owners

For a US-formed LLC, the current federal BOI rule starts with the entity's place of formation: Domestic entities are excluded from the current federal reporting-company definition. (source)

That federal exemption is not a promise of anonymity. BOI already reported to FinCEN follows this confidentiality rule: BOI reported to FinCEN is confidential except for authorized disclosures in 31 CFR 1010.955. (source)

Continue to state beneficial-ownership disclosure laws.

For an entity that still has a reporting duty, accuracy and updates still matter: Willful false BOI reporting or willful failure to report complete/updated BOI is unlawful under 31 CFR 1010.380(g). (source) Reporting companies must file updated reports within 30 days after required information changes. (source)

How this page stays current

Each legal or date claim on this page is transcluded from a source-bound cell that carries last-checked metadata.

Not established: a fixed review cadence. The evidence universe does not include a vetted cadence value.

If you find an error, use the corrections route. This page is informational and is not legal advice.

Frequently asked questions

Related research

• What is the Corporate Transparency Act?Background on the federal act behind BOI reporting.
• Foreign reporting company BOI rulesA focused guide to the remaining foreign-company reporting class.
• State beneficial-ownership disclosure lawsThe state-law layer beside the federal BOI regime.
• Who can access an LLC's beneficial-owner information?A broader view of access beyond this federal timeline.