FinCEN Permanently Ends Enforcement of Beneficial Ownership Reporting Requirements – For Now

For those who have been following along with the Corporate Transparency Act and the beneficial ownership information (BOI) reporting requirements, amongst the many legal challenges and delays in the reporting deadlines, there has been a lot of “will they, won’t they” when it comes to whether the Financial Crimes Enforcement Network (FinCEN) will reinstate enforcement of the Act and institute a new reporting deadline.

On August 11, 2026, FinCEN finally provided an answer by finalizing a rule that will permanently remove the requirement for U.S. companies and U.S. persons to report beneficial ownership information to FinCEN, thereby providing a new broad reporting exemption. Additionally, for any U.S. companies and persons who have already reported their information to FinCEN before any of the reported deadlines, FinCEN will delete all such information from its database.

Additionally, FinCEN’s new rule eliminates the requirement for any U.S. person to update or correct information that they provided in order to obtain a FinCEN ID, whether as a beneficial owner or company applicant.

While U.S. companies and U.S. persons are now exempt from the reporting requirements, foreign entities and pooled investment vehicles that qualify as reporting companies under the Act are still required to report the beneficial ownership information for foreign persons. Any U.S. person who helped register these foreign entities will not be required to report.

While enforcement and reporting requirements may change under future administrations, as the Act itself has not been repealed by Congress, for the time being, U.S. persons are free from the burden of meeting the BOI reporting requirements or updating the information they provided to receive their FinCEN ID.

If you have any questions on this update, please reach out to our Business Transactions Group.