BOI after the 2026 final rule: who still files
FinCEN no longer requires beneficial-ownership reports from US-formed companies. What changed on 14 August 2026, who remains in scope, and what FormBridge does about it.
A FinCEN final rule effective 14 August 2026 permanently exempts every entity created in the United States — and its beneficial owners — from Beneficial Ownership Information reporting. The exemption turns on where the entity was formed, not on who owns it. A Wyoming LLC owned entirely by a non-resident founder is a domestic entity and is exempt.
The Beneficial Ownership Information (BOI) report is a US federal filing to FinCEN (the Financial Crimes Enforcement Network) identifying the individuals who ultimately own or control a company. Until August 2026 it applied to most US LLCs and corporations, with a 90-day-from-formation deadline. It no longer does.
Who still files
One group remains in scope: a foreign reporting company — an entity formed outside the United States that is registered to do business in a US state or Tribal jurisdiction, and not otherwise exempt. Registering a non-US entity to trade in a US state is what creates the obligation; forming a company abroad does not, on its own.
- A foreign reporting company reports only its non-US-person beneficial owners. It does not report BOI for any US-person beneficial owner or company applicant.
- For each in-scope individual: full legal name, date of birth, residential address, and government ID.
- The 30-day update obligation — refiling when ownership details change — applies only while the company stays in scope.
What FormBridge does
- 1No BOI obligation is calendared for US entities
The Compliance agent's jurisdiction rules no longer emit a BOI task for any entity formed in a US state, and the compliance calendar will not show one. If you hold a task created before the rule changed, the daily reconcile waives it rather than deleting it, so the record of why it closed stays on the ledger.
- 2Your Trust Center reports the exemption, not a blank
The BOI tile reads "Not required" with the rule and its date, so a bank or investor reviewing your page sees a settled position rather than an unanswered question.
- 3We do not assess whether you are exempt
FormBridge tracks the current federal position and acts on it. Whether a particular entity is a foreign reporting company is a legal determination we do not make for you.
State law is separate. The federal exemption says nothing about state-level beneficial-ownership regimes, such as New York's LLC Transparency Act, which are unaffected and may still apply. And this requirement has reversed twice in three years. Confirm the current position at FinCEN.gov before acting, particularly if you registered a non-US entity to do business in a US state. This is not legal advice.
Your remaining recurring obligations — annual reports, franchise tax, registered-agent renewals — are on the compliance calendar.