BOI Reporting Deadlines: Key Dates for Compliance

Recent Developments

On March 21, 2025, FinCEN issued an interim final rule removing the requirement for U.S. companies and U.S. persons to report beneficial ownership information. On August 11, 2026, FinCEN issued a final rule, effective August 14, 2026, that made those exemptions permanent. As a result:

• Companies created in the United States are exempt from BOI reporting and have no filing deadline. If your U.S. company filed before the rule changed, you are not required to update or correct the report.
• Foreign companies registered to do business in the U.S. remain reporting companies and must meet the deadlines below unless they qualify for one of the CTA's 23 exemptions.
• U.S. persons are not reported. A foreign reporting company does not report beneficial owners or company applicants who are U.S. citizens or lawful permanent residents.

Foreign Companies Registered Before March 26, 2025

Foreign companies that were already registered to do business in the United States when the interim final rule was published were required to file their initial BOI report by April 25, 2025. That date has passed. If your company has not yet filed, it should do so immediately to limit exposure to daily penalties.

• Required Information: Company legal name, trade names, U.S. business address, foreign jurisdiction of formation, state of first U.S. registration, and tax identification number, plus full name, date of birth, residential address, and identification for each beneficial owner who is not a U.S. person.
• BOIR E-FILE System: Use our online E-File System for submitting BOI reports. For detailed steps, refer to our guide on The BOIR Filing Process: A Complete Guide for Foreign Reporting Companies.

Foreign Companies Registered On or After March 26, 2025

A foreign company that registers to do business in a U.S. state or tribal jurisdiction on or after March 26, 2025 must file its initial BOI report within 30 calendar days. The clock starts on the earlier of the date the company receives actual notice that its registration is effective or the date the secretary of state (or similar office) first provides public notice of the registration.

• Plan ahead: Thirty days passes quickly. Gather owner identification documents before or at the time of registration so the filing can be submitted as soon as the registration is effective.

Ongoing Reporting Obligations

There is no annual BOI filing. However, any change to the information previously reported must be filed with FinCEN within 30 calendar days of the change. Examples include a new beneficial owner who is not a U.S. person, a change in a reported owner's address or identification document, a new trade name, or a change in the company's U.S. business address. Corrections to inaccurate information are due within 30 calendar days of becoming aware of the inaccuracy.

• Compliance Importance: Promptly update ownership records to avoid fines and remain compliant.
• Continuous Monitoring: Ensure accurate and up-to-date information by establishing a compliance process for ongoing reporting obligations.