Do You Need to File a BOI Report for Your LLC in 2026?

If your LLC was formed in the United States, no. As of August 2026 you have no beneficial ownership reporting obligation to FinCEN, and you should not pay anyone to file one for you. That is a real change from the rule most formation checklists still describe, so here is what happened and what it means for a company you are starting right now.

What changed

The Corporate Transparency Act required most small companies to report their beneficial owners, meaning the real people who own or control the business, to the Financial Crimes Enforcement Network. Millions of LLCs filed. In March 2025 FinCEN issued an interim rule narrowing who had to report, and on August 11, 2026 it made that narrowing final, published in the Federal Register on August 14, 2026 and effective on publication (fincen.gov).

The effect is simple. In FinCEN's own words, U.S. companies and U.S. persons are no longer required to file. Entities created in the United States sit outside the definition of a reporting company, so there is nothing to submit, no deadline to miss, and no penalty hanging over you for missing it.

FinCEN also said it will delete information previously reported by U.S. persons from the beneficial ownership database. If you filed a BOI report in 2024 or 2025, there is no withdrawal form to chase.

Who does still file

The requirement did not disappear for everyone. Under federal law, foreign entities that are reporting companies still report beneficial ownership information for foreign individuals (fincen.gov). In practice that means a company formed under the law of another country and then registered to do business in a U.S. state. If you formed a Delaware, Wyoming, Texas or other U.S. state LLC, this is not you.

What it costs, and what it should cost

This belongs in a startup cost conversation because BOI filing became a product. Formation services, registered agents and filing companies sold it as a paid add-on, often folded into an annual compliance package.

Two things are worth knowing. Filing directly with FinCEN never carried a fee (fincen.gov), so any charge was for the convenience of someone else typing your information into a form. And now there is no filing to make at all. If a service offers to prepare or file your BOI report for a fee, or renews a compliance bundle that lists one, that is a line item you can delete from your first-year budget. FinCEN has also warned that correspondence requesting payment in connection with beneficial ownership reporting may be fraudulent, which is worth remembering if an official-looking filing notice turns up in the mail.

Your state is a separate question

Federal rules are not the whole picture. New York passed its own LLC Transparency Act, which took effect on January 1, 2026 and created a state-level beneficial ownership filing with the New York Department of State.

For most readers the answer there is still no. New York's act defines a reporting company by reference to the federal statute, and guidance from the New York Department of State confirms that only LLCs formed outside the United States and authorized to do business in New York fall under it (dos.ny.gov). An LLC formed in New York, or in any other U.S. state, files neither a disclosure nor an attestation of exemption. A non-U.S. LLC authorized to do business in New York files one or the other, with a $25 fee, within 30 days of its application for authority.

Other states have floated similar bills without passing them. Check your own secretary of state or department of state before assuming the federal answer settles it for you.

Could this change again

It could, and that is worth saying plainly. The Corporate Transparency Act itself is still on the books. What changed is the rule FinCEN wrote to carry it out, and a later rulemaking or a court decision could move the line again. This post describes the position as of September 2026. If you are reading it well after that, confirm at fincen.gov/boi before you act on it.

The short version

• U.S.-formed LLC or corporation: nothing to file with FinCEN.
• Already filed in 2024 or 2025: nothing to withdraw, and FinCEN says it will delete U.S. person data.
• Foreign-formed entity registered in a U.S. state: you may still report, so check fincen.gov.
• New York: only non-U.S.-formed LLCs file with the state.
• Paying a service for BOI filing: cancel it.