Do you still have to file a BOI report?

How we got here, in four sentences

The Corporate Transparency Act, passed in 2021, required most small US companies to tell FinCEN who ultimately owns them, and the reporting window opened January 1, 2024. Then came a year of litigation — injunctions granted, stayed, and reinstated — during which the deadline switched on and off enough times that nobody could tell you on a given Tuesday whether filing was mandatory.

In March 2025, FinCEN ended the whiplash with an interim final rule: US-formed companies were out, and only foreign companies registered to do business in the US remained on the hook. On August 11, 2026, FinCEN issued the final rule making that permanent, effective August 14, 2026.

So the answer to the title question stopped being complicated. Formed in a US state? You don't file. There is no deadline coming, no grace period running out, and no penalty accruing — whatever an official-looking envelope is telling you.

Who still files: foreign-formed companies, and only them

The final rule rewrote the definition of "reporting company" to cover exactly one group: entities formed under the law of a foreign country that have registered to do business in a US state or tribal jurisdiction. A German GmbH registered to operate in Texas files. A Texas LLC owned by a German citizen does not — the test is where the company was formed, never who owns it.

Even the foreign companies that still file got a lighter version of the rule. They don't report US-person beneficial owners, and they don't report US company applicants. The filing deadlines for foreign registrants are tied to when the US registration takes effect; if that's you, get the current dates from fincen.gov/boi directly rather than from a blog post — including this one.

If you're reading this as the owner of an ordinary American LLC, none of that paragraph applies to you. You have no FinCEN filing, and nobody legitimate will ever bill you for one.

The scam letters, because that's probably why you're here

The BOI requirement died, but the mail demanding money for it did not. Businesses are still receiving letters — and emails, and texts — dressed up as government correspondence: an eagle in the corner, a name like "US Business Regulations Department" or "Annual Compliance Division", a form number that sounds plausible, a deadline a week out, and a fee. Some carry QR codes pointing at a payment page. Some cite the real penalty figures from the original 2024 rules to make the threat land.

Here is everything you need to evaluate any of them. FinCEN filing was free even when it was mandatory — the government never charged a cent to submit a BOI report. FinCEN does not send unsolicited letters demanding payment, and no state agency collects BOI on its behalf. And since August 2026, a US-formed company has no BOI obligation for anyone to enforce. Every element of the letter — the fee, the urgency, the agency name — fails on its own.

So: don't pay, don't scan the code, don't call the number on the letter. If you want to report it, the FTC takes fraud reports at reportfraud.ftc.gov, and your state attorney general's office will usually want to see it too. Then throw it away. The one thing these letters exploit is the reasonable instinct that a compliance notice must be about something real — check anything against the agency's own .gov site and that instinct stops being expensive.

What happens to the reports people already filed

Millions of companies filed during the 2024 window, handing FinCEN names, birthdates, addresses, and copies of driver's licenses. Along with the final rule, FinCEN announced it will delete the previously reported information of US persons from the BOI database. US persons who obtained FinCEN identifiers are also relieved of the duty to keep that information updated.

There's nothing you need to do to trigger the deletion, and no filing that undoes your old report faster. If you filed in 2024 and have been wondering whether you now owe update reports every time someone moves — you don't.

What you still owe, because it isn't nothing

BOI was a federal filing, and its death changes nothing at the state level. Your state still expects its annual report — that's the filing that keeps the LLC in good standing, and missing it still ends in late fees and eventually administrative dissolution. If a compliance notice is real, it's almost certainly this one.

The rest of the list is the usual: keep the registered agent current, renew any licenses or permits that expire, and file the tax returns you'd file anyway. If you're forming a new company, the checklist got one item shorter — you form the LLC, get the EIN, open the bank account, and there is no FinCEN step. We handle the formation part for $100 flat plus your state's fee if you'd rather not do the paperwork; there's genuinely nothing to sell you on the BOI front, because the filing no longer exists for you.

Common questions