By Industry Advisors · Updated December 2026 · ~7 min read
The Corporate Transparency Act's Beneficial Ownership Information (BOI) requirement has been through more legal on-off switches than any federal filing in memory. As of late 2026 the rules are back on for most U.S. LLCs, penalties are real, and the FinCEN portal is quietly processing millions of filings a week. If you formed, transferred, or changed control of an LLC in 2024, 2025, or 2026 and haven't filed, this post is the fast catch-up.
Where BOI Stands In Late 2026
After a chaotic 2024–2025 (multiple injunctions, one Supreme Court stay, one revised Treasury rule limiting the scope for domestic entities), the current 2026 framework applies primarily to LLCs that formed or registered after January 1, 2024 and to entities with foreign ownership. Always check the current status at the FinCEN BOI portal before assuming you're covered or exempt — the rule has moved more than once.
Who Has To File (And Who's Exempt)
Generally required to file:
- LLCs formed on or after January 1, 2024
- Foreign entities registered to do business in the U.S.
- Any LLC with foreign beneficial owners (regardless of formation date)
Common exemptions (23 categories at FinCEN):
- "Large operating company" — 20+ full-time U.S. employees, $5M+ gross receipts, physical U.S. office
- Publicly traded companies, banks, credit unions, SEC-registered investment advisers, insurance companies
- 501(c) tax-exempt entities
- Inactive entities (specific narrow criteria)
The full exemption list is at the FinCEN BOI FAQ. Most single-owner and small-partnership LLCs do not qualify for any exemption.
What The Report Actually Asks For
Two categories of information:
- Reporting company: Legal name, DBAs, EIN, formation state, business address
- Each beneficial owner (anyone with 25%+ ownership OR who exercises substantial control): full legal name, DOB, current residential address, unique ID number from a passport / driver's license / state ID, and a scan/photo of that ID
- For entities formed after Jan 1, 2024: Same information for each company applicant (the person who filed the formation)
Each individual can request a FinCEN Identifier once — after that, subsequent filings can reference the ID rather than re-uploading personal information across every LLC you own.
Deadlines
- Initial report for entities formed on or after January 1, 2024: within 30 calendar days of formation approval
- Updated report: within 30 days of any change in beneficial ownership information (new owner, address change, name change, new government ID)
- Corrected report: within 30 days of discovering an inaccuracy
The 30-day updated-report clock is the one people miss. Move houses? File within 30 days. New partner? Same. Married and changed your name? Same.
How To File — The 20-Minute Walkthrough
- Go to boiefiling.fincen.gov
- Choose "File BOIR"
- Enter reporting company info (name, EIN, address)
- Add each beneficial owner: name, DOB, address, ID number + scan of the front of a passport / driver's license
- Add each company applicant (only for 2024+ formations)
- Submit; save the transcript PDF
Filing is free. Third-party services charging $75–$300 for the filing are re-selling the same free portal.
Quick Tool — Is your BOI current?
Answer honestly:
Penalties
Willful violations carry civil penalties of up to $591/day (2026 adjusted amount) and criminal penalties up to $10,000 and 2 years in prison. Practical enforcement in 2025–2026 has focused on egregious cases (fraud, willful nondisclosure of foreign owners) rather than sweep-audits of small LLCs. That's not permission to skip; it's just the current pattern.
Cross-reference our 2026 founder compliance calendar, how to form an LLC, and Q4 compliance checklist. Also see the SBA stay-compliant guide and the FinCEN BOI portal.
File Your BOI Report Cleanly And On Schedule
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