Last week, FinCEN finalized the sweeping rollback of the Corporate Transparency Act (CTA) beneficial ownership information (BOI) reporting requirements that Treasury initiated last year—and provided some additional relief for US persons in the process.
On August 11, FinCEN announced its issuance of a final rule permanently adopting the March 2025 interim final rule’s exemption of domestic entities from the BOI reporting requirements. The final rule, effective August 14, also continues the exemption for US persons who are beneficial owners of foreign reporting companies and extends that relief to US person company applicants. US persons who previously obtained FinCEN identifiers (FinCEN IDs) also will no longer be required to update or correct the information they provided to obtain those identifiers.
As we reported in March 2025, Treasury had announced that it would not enforce the CTA’s BOI reporting requirements against US citizens, domestic reporting companies, or their beneficial owners and planned to narrow the reporting rule to foreign reporting companies. FinCEN implemented that policy through its March 2025 interim final rule. The new final rule makes those changes permanent. Domestic companies are no longer “reporting companies” under FinCEN’s CTA regulations and therefore have no obligation to file initial, updated or corrected BOI reports.
The final rule also provides two additional forms of relief for US persons: (1) Foreign reporting companies no longer have to report BOI for US person company applicants, just as they were already exempt from reporting BOI for US person beneficial owners; and (2) US persons with FinCEN IDs no longer need to update or correct the information previously submitted to obtain those IDs.
FinCEN also announced that it will delete previously reported information of US companies and US persons from its BOI database. The agency says it plans to identify and remove, as much as practicable, information that would not have been required had the final rule been in effect when reporting began. FinCEN does not currently expect US companies or US persons to request deletion and does not plan to provide individual confirmation; instead, it will announce publicly when the deletion process is complete.
The CTA is not entirely out of the picture, however. Entities formed under the laws of a foreign country that register to do business in a US state or Tribal jurisdiction remain potentially subject to the BOI reporting requirements. Those companies generally must continue to report required entity information and BOI for reportable non-US beneficial owners, but not for US person beneficial owners or company applicants.
FinCEN estimates that approximately 27.5 million domestic reporting companies have been relieved of reporting obligations since issuance of the interim rule, with significant reductions in compliance costs and burden hours.
See FinCEN’s FAQs, this McGuireWoods post, and our Corporate Transparency Act page for additional information and resources.