BOI Filing Guide: Who Still Has to File After March 2025

Beneficial Ownership Information (BOI) Filing Guide

The Corporate Transparency Act created the BOI report, which tells FinCEN who owns or controls a company. The rules changed significantly in March 2025, and most US LLCs no longer have to file.

US-formed companies are exempt

FinCEN's interim final rule of 21 March 2025 exempts every entity created in the United States, and its beneficial owners, from BOI reporting. That includes LLCs and corporations owned by non-residents, such as a Wyoming or Delaware LLC owned by a founder in India.

Who still has to file?

Only foreign reporting companies: entities formed under the law of another country that have registered to do business in a US state by filing with a secretary of state. An Indian private limited company that registers in Delaware is an example. Foreign reporting companies do not have to report US persons as beneficial owners.

Deadlines

A foreign reporting company must file within 30 calendar days of its US registration becoming effective. If reported information changes later, an updated report is due within 30 days of the change. BOI is not an annual filing.

What information is required?

For each beneficial owner (anyone with 25% or more of the ownership, or substantial control): full legal name, date of birth, residential address, and an identifying number and image from a passport or driver's licence.

Could this change?

Yes. The March 2025 rule is an interim final rule that FinCEN has said it will finalise, so check fincen.gov/boi for the current position before relying on an exemption.