Beneficial ownership reporting in 2026: what a US-formed company owes FinCEN

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.

• 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.
• 11 August 2026. FinCEN issued a final rule making both exemptions permanent. It took effect on 14 August. In FinCEN's words, US companies "are no longer required to file BOI reports."

No beneficial ownership report. 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.

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 within 30 calendar days of being told their registration is effective. A company formed abroad that then registers in Delaware as a foreign entity has to report. A company formed in Delaware doesn't.

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.

FinCEN also still receives the FBAR, a separate yearly report of accounts held outside the US. A US-formed company files one only if those accounts held more than $10,000 between them at any time in the year. A company that banks only in the US doesn't file one.