Is BOI Reporting on Hold? 2026 Final Rule

Originally published December 16, 2024. Updated August 23, 2026.

Quick answer: No. For companies created in the United States, BOI reporting is no longer simply on hold. FinCEN’s final rule, effective August 14, 2026, exempts U.S. companies from the federal Beneficial Ownership Information reporting requirement.

The situation has changed significantly since this article was originally published. The December 2024 court ruling created a temporary pause, but it is no longer the main reason most U.S. small businesses do not have to file.

Here is what business owners need to know now.

Is BOI Reporting on Hold in 2026?

No. For U.S. created companies, BOI reporting is no longer a temporary pause.

The Financial Crimes Enforcement Network, commonly called FinCEN, issued a final rule making its BOI reporting exemptions permanent under the current regulation. The rule became effective August 14, 2026.

According to FinCEN’s current BOI guidance:

• U.S. companies are exempt from BOI reporting.
• U.S. persons do not need to provide their BOI to reporting companies.
• Reporting companies do not report information about U.S. person beneficial owners or company applicants.
• U.S. persons with FinCEN IDs do not need to update or correct information they previously submitted to obtain those IDs.

This is different from the temporary court-ordered pause discussed in the original version of this article.

What Changed Since December 2024?

The BOI reporting situation went through several major changes:

• In December 2024, a federal court temporarily stopped enforcement of the reporting requirements nationwide.
• In March 2025, FinCEN issued an interim final rule exempting U.S.-created entities and U.S. persons from BOI reporting.
• On August 11, 2026, FinCEN announced its final rule.
• The final BOI rule became effective August 14, 2026.

The earlier advice to gather identification documents and wait for the court case to be resolved is no longer appropriate for a typical U.S. created company.

Does a U.S. LLC or Corporation Need to File a BOI Report?

Under the current final rule, an entity created in the United States is exempt from the federal BOI reporting requirement.

This includes entities that were previously called “domestic reporting companies.” For example, a typical LLC or corporation created under Colorado law is considered a U.S.-created entity and is exempt under the current rule.

This exemption applies even if the company would have been required to report under the original BOI rules.

Business owners should still confirm where and how their entity was legally created. A business operating in the United States is not necessarily a U.S. created entity if it was originally formed under the law of another country. Be sure to confirm the status of your unique small business.

What If My Company Already Filed a BOI Report?

A U.S. created company that filed a BOI report before the exemption took effect is not required to file updated or corrected BOI reports under the current rule.

FinCEN also states that U.S. persons with a FinCEN ID are not required to update or correct the information they previously submitted when obtaining that ID.

You may want to keep your original filing confirmation with your business records. However, the current rule does not require a U.S. created company to continue updating that BOI report.

Who May Still Need to Report BOI?

Certain foreign entities may still have BOI reporting responsibilities.

FinCEN’s current definition of a reporting company generally applies to an entity that:

1. Was formed under the law of a foreign country.
2. Registered to do business in a U.S. state or Tribal jurisdiction.
3. Does not qualify for another exemption.

These foreign reporting companies generally do not have to report information about U.S. person beneficial owners or U.S. person company applicants.

FinCEN states that covered foreign entities registered before March 26, 2025, had an April 25, 2025, reporting deadline. A covered foreign entity registered on or after March 26, 2025, generally has 30 calendar days after receiving notice that its U.S. registration is effective.

A foreign entity that may have missed a deadline should speak with an attorney or qualified compliance advisor promptly. Perlinger Consulting does not provide legal advice or prepare BOI reports.

How Can Business Owners Avoid BOI Scams?

FinCEN continues to warn businesses about fraudulent BOI notices.

Be cautious if you receive a letter, email, text message, or phone call requesting payment or personal information related to BOI reporting.

FinCEN specifically warns that:

• There is no fee to file a BOI report directly with FinCEN.
• “Form 4022” and “Form 5102” are fraudulent.
• The “US Business Regulations Dept.” is not a real government agency.
• FinCEN does not send initial penalty notices by email or telephone.
• Suspicious links and QR codes should not be opened or scanned.

Do not send identification, ownership information, or payment until you have verified the sender through an official government source.

What Should a Small Business Owner Do Now?

Start by confirming whether your business was created under U.S. law or foreign law.

If your company was created in the United States, save a link to FinCEN’s current guidance with your company records. You do not need to collect owners’ identification documents for a federal BOI filing under the current rule. Trust but VERIFY!

If your entity was formed under the law of another country and registered to operate in the United States, consult an attorney or qualified compliance advisor about your specific reporting responsibilities.

Because regulations can change, rely on FinCEN’s official BOI page instead of an old article, social media post, email, or solicitation.

Does the BOI Exemption Change Other Business Responsibilities?

No. BOI reporting is separate from your other business responsibilities.

Depending on your company, state registrations, licenses, payroll filings, sales tax obligations, accounting records, and other requirements may still apply. The BOI exemption does not replace accurate bookkeeping or organized business records.

Perlinger Consulting provides monthly bookkeeping services, bank and credit card reconciliations, QuickBooks cleanup, reporting support, and customized QuickBooks training. We do not prepare income tax returns or provide legal advice.

The Bottom Line

BOI reporting is not simply “on hold” for U.S. companies. FinCEN’s final rule exempts companies created in the United States from the federal BOI reporting requirement.

Certain foreign entities registered to do business in the United States may still need to report. Those entities should review FinCEN’s current requirements and obtain appropriate legal guidance.

Perlinger Consulting, Inc. has been serving small businesses since 2001. We support businesses in Littleton, Centennial, the Denver Metro area, and nationwide online.

If your BOI question is resolved but your bookkeeping still needs attention, schedule a free 14-minute consultation with Glenn.

Disclaimer: This article provides general educational information and is not legal or tax advice. BOI rules and government guidance can change. Review current FinCEN guidance and consult an attorney or other qualified advisor regarding your particular entity.

AI-assisted research, art and drafting. The professional perspective and final decisions are ours.