FinCEN Begins Accepting Beneficial Ownership Reports

By Erik Lincoln, JD, CPA | Lincoln PLLC – Updated June 2026

When FinCEN began accepting beneficial ownership information (BOI) reports on January 1, 2024, it marked the effective launch of the Corporate Transparency Act’s (CTA) reporting framework. Since then, the CTA has gone through multiple court injunctions, deadline extensions, and a significant regulatory reversal. If you are a business owner or CPA trying to understand where things stand today, this post summarizes the current state of BOI reporting as of mid-2026.

Where Things Stand: U.S.-Formed Entities Are Now Exempt

On March 26, 2025, FinCEN issued an interim final rule that fundamentally changed the scope of the CTA’s reporting requirements. Under that rule, all entities formed in the United States – previously known as domestic reporting companies – and their beneficial owners are now exempt from the requirement to report BOI to FinCEN. The interim final rule revised the definition of “reporting company” to cover only entities formed under foreign law that are registered to do business in a U.S. state or tribal jurisdiction.

As a practical matter, this means that most U.S. businesses – LLCs, corporations, and other entities formed by filing with a U.S. secretary of state – no longer have a BOI reporting obligation under the federal CTA framework. The civil and criminal penalties that originally applied to non-compliant domestic companies are no longer in play for those entities.

Who Still Has Reporting Obligations?

Foreign reporting companies – entities formed under foreign law that are registered to do business in the United States – continue to have BOI reporting obligations under the interim final rule. These entities are not required to report U.S. persons as beneficial owners, and U.S. persons are not required to provide BOI to a foreign reporting company for which they are a beneficial owner. Foreign reporting companies that registered to do business in the U.S. before March 26, 2025, were required to file by April 25, 2025. Companies registered after that date have 30 calendar days from receiving notice of effective registration to file their initial report.

State-Level Considerations

The federal exemption for domestic entities does not eliminate all beneficial ownership disclosure requirements. Some states have enacted or are considering their own transparency rules. New York’s LLC Transparency Act, for example, took effect January 1, 2026, and imposes disclosure requirements on certain LLCs formed in New York or authorized to do business there. Business owners and their advisors should confirm whether any applicable state laws create additional obligations independent of the federal CTA framework.

What This Means for Businesses and Their Advisors

CPAs and attorneys who spent considerable time in 2023 and 2024 advising clients on CTA compliance now face a different set of questions: what state-level obligations may apply, whether any prior FinCEN filings require updating or correction, and how the ongoing regulatory process – FinCEN has indicated it intends to finalize the rule – may affect future requirements.

The CTA’s regulatory landscape remains in flux. FinCEN is still accepting comments on the interim final rule and intends to issue a final rule. Legislative proposals that would further modify the CTA continue to be introduced. Businesses with international operations, foreign owners, or plans to register entities in multiple jurisdictions should continue monitoring developments and consult with qualified tax and business law counsel before assuming their reporting obligations are fully resolved.

Lincoln PLLC counsels businesses and professional advisors on CTA compliance questions, international tax matters, and business entity structuring. If you have questions about how the current BOI framework applies to your business, contact our firm to schedule a consultation.

Erik Lincoln is a founding member of Lincoln. In addition to being an attorney he is also a CPA. Erik has consistently been recognized as one of the top attorneys in North Carolina, by Business North Carolina.