For two years, the beneficial ownership report was the filing every formation company sold and every founder abroad worried about. For companies formed in the United States, it's over. This guide is short because the answer is.
What happened
- 1 January 2024. The Corporate Transparency Act took effect, and most US companies had to report their beneficial owners to FinCEN, with penalties for not doing so.
- March 2025. After court challenges and a change of administration, FinCEN issued an interim final rule exempting every company formed in the US, and exempting US persons from being reported by anyone.
- 14 August 2026. A final rule made both exemptions permanent. FinCEN and the Treasury announced it as the end of beneficial ownership reporting for US companies.
What a US-formed company owes now
Nothing. A Wyoming LLC or a Delaware corporation formed by a founder abroad counts as a domestic company under the rules, and domestic companies are exempt. There's no initial report, no update and no yearly confirmation. If a provider still lists a BOI filing as part of its plan, it's listing a filing you don't owe.
Who still files
Only foreign reporting companies: entities formed under another country's law that have registered to do business in a US state by filing with a Secretary of State. They report their non-US beneficial owners. A company formed abroad that then registers in Delaware as a foreign entity has to report. A company formed in Delaware doesn't.
What hasn't changed
Banks still identify beneficial owners when you open an account, under separate customer due diligence rules, which is why Mercury asks for the passport of every owner of 25% or more. The IRS still learns who owns a foreign-owned LLC from Form 5472. And your own country's rules on reporting companies you own abroad aren't affected by anything FinCEN does.