BOI reporting after 2025: who still files with FinCEN

Beneficial ownership reporting under the Corporate Transparency Act began in 2024, then changed sharply in March 2025. Most US companies, including LLCs owned by people abroad, no longer file. Here is where things stand and what has not changed.

William Sunjo M.Operations and compliance editor

Published: 3 September 2026
Reading time: 2 min read

The Corporate Transparency Act asked millions of small US companies to report their owners to FinCEN, starting in 2024. After court challenges and a policy change, FinCEN published an interim final rule in March 2025 that narrowed the duty to a small group of foreign companies. If you run a US LLC from abroad and spent part of 2024 worrying about BOI, here is the current picture.

What changed in March 2025

The interim final rule:

exempted all entities created in the US, previously called domestic reporting companies, from BOI reporting,
kept the duty only for foreign reporting companies,
removed any need for foreign reporting companies to report US persons as beneficial owners.

FinCEN said it would finalize the rule later. Check its BOI page for the current status before any filing decision.

Who still files

Entity	Files BOI?
Delaware LLC owned by a founder in Brazil	No, it is a domestic company
Wyoming LLC owned by a UK company	No, it is a domestic company
UK Ltd registered with a US state to do business there	Yes, as a foreign reporting company
German GmbH not registered with any US state	No

The test is where the entity was formed, not where its owners live. A US LLC owned entirely by non-residents counts as domestic and is exempt.

Deadlines for foreign reporting companies

A foreign company that registers to do business in a US state after the interim rule has 30 calendar days from when its registration takes effect. The report lists the company and its non-US beneficial owners.

What has not changed

Your bank still asks. Banks and payment providers collect ownership information under their customer due diligence rules, separately from BOI. Expect to name everyone with 25% or more and a person with significant control. The beneficial owner guide explains the test.

Form 5472 still applies. A foreign-owned single-member US LLC still files Form 5472 with the IRS every year. That duty has nothing to do with BOI. See the Form 5472 guide.

State rules still apply. Annual reports, registered agents and franchise taxes continue as before. The Delaware vs Wyoming guide covers them.

This article explains the rules in general terms. It is not legal advice.

On Rivet

Rivet opens accounts for US LLCs owned by people abroad and asks for the ownership details once, during verification. See Bank accounts.

Questions people ask

Does my US LLC need to file a BOI report?

Under FinCEN's March 2025 interim final rule, no. Companies formed in the US are exempt, whoever owns them. Check FinCEN's BOI page for any later change before relying on this.

Who still has to file BOI reports?

Foreign reporting companies: entities formed under foreign law that have registered to do business in a US state or tribal jurisdiction by filing a document with a secretary of state or similar office.

What is the deadline for foreign reporting companies?

Under the interim rule, a foreign company registered on or after the rule's publication has 30 calendar days from when its registration becomes effective.

Do I still give ownership details to my bank?

Yes. Banks and payment providers collect beneficial ownership information under their own customer due diligence rules. The BOI change did not affect that.

Sources

Written by

William Sunjo M.

Operations and compliance editor

William covers what happens once a company starts moving money: getting the business verified, paying contractors and suppliers abroad, and keeping card spend under control. William writes for the founder or finance lead who has to make it work this week, and links every rule cited to the text it comes from.