Foreign Reporting Company BOI Rules (federal regime matrix, post-March 2025 IFR)
Federal regime matrix. Source: FinCEN Interim Final Rule 90 FR 13688 (March 26, 2025). Last checked: 2026-05-13. Not legal advice.
Matrix data
| Entity type | Subject to federal BOI reporting? | Source |
|---|---|---|
| Foreign-formed entity created before March 26, 2025 | Yes — foreign reporting companies remain subject | FinCEN IFR Q&A (fincen.gov/boi/ifr-qa) |
| Foreign-formed entity created on or after March 26, 2025 | Yes — foreign reporting companies remain subject | FinCEN IFR Q&A (fincen.gov/boi/ifr-qa) |
| US-formed LLC | No — exempt per the March 26, 2025 IFR | FinCEN news release (fincen.gov/news/news-releases) |
| US-formed corporation | No — exempt per the March 26, 2025 IFR | FinCEN news release (fincen.gov/news/news-releases) |
Research scope and caveats
This matrix tracks the FEDERAL Corporate Transparency Act BOI reporting regime as revised by FinCEN's March 26, 2025 Interim Final Rule (90 FR 13688). State-level BOI analogs (NY LLC Transparency Act; CA SB proposals) are separate regimes tracked separately.
Terminology trap: "foreign LLC" in state corporate law means out-of-state (e.g., a Wyoming LLC operating in California). In the federal CTA context, "foreign reporting company" means an entity formed under the laws of a foreign country. A Wyoming LLC is NOT a foreign reporting company — it is a US-formed entity and is exempt under the IFR.
NY LLC Transparency Act: applies only to non-US foreign-country LLCs per the official NY DOS FAQ. US out-of-state LLCs are exempt. See companion page Who Still Knows the Beneficial Owner of an LLC?.
Confidential per statute ≠ private in practice. For foreign reporting companies subject to BOI, the data is confidential per 31 U.S.C. §5336 but not air-gapped. Federal databases breach; social engineering is the dominant attack surface; and the authorized-requestor list under §5336(c) is broader than founders typically assume.
This matrix does NOT make 50-state claims and does not address state-level BOI regimes. Pages do NOT make 50-state claims.
How to read this matrix
Each row represents an entity formation type. Typed unknowns mark fields that cannot be confirmed under the methodology at /about/methodology/.
Sources
Primary source: FinCEN IFR (90 FR 13688, March 26, 2025). Official Q&A at fincen.gov/boi/ifr-qa. Refresh cadence: trigger-event-driven (FinCEN regulatory finalization). Full source taxonomy at /about/source-registry/.
Not legal advice
BOI compliance depends on entity formation jurisdiction, corporate structure, and specific facts. The IFR is an interim rule; a final rule may differ. Consult counsel for compliance-specific questions.
Frequently asked questions
Is a Wyoming LLC a foreign reporting company under the CTA?
No. In federal CTA terminology, foreign means formed outside the United States. A Wyoming LLC is US-formed and exempt under the March 26, 2025 IFR (90 FR 13688).
Do foreign-formed entities created before March 26, 2025 still report?
Yes — FinCEN IFR Q&A states foreign reporting companies created before that date remain subject.
Is BOI data public like a state business registry?
No. BOI is confidential per 31 U.S.C. §5336, but confidentiality is not air-gapped — authorized requestors under §5336(c) exceed what many founders assume.
How does this relate to the New York LLC Transparency Act?
NY applies to non-US foreign-country LLCs per NY DOS FAQ — US out-of-state LLCs are exempt. State BOI analogs are tracked separately from this federal matrix.
Where is the FinCEN primary source cited?
FinCEN IFR 90 FR 13688 (March 26, 2025) and fincen.gov/boi/ifr-qa — tiered in /about/source-registry/ with trigger-event refresh.
Go deeper with source-backed research
Explore methodology, datasets, and related matrices cited on this page.