Corporate Transparency Act / BOI timeline

TL;DR: A U.S.-formed LLC or corporation is not required to file a BOI report as of June 26, 2026. The remaining BOI filing question is mainly for foreign-formed entities that registered to do business in a U.S. state.

What is the current BOI answer for a U.S.-formed LLC?

The answer is no BOI filing right now. FinCEN's March 26, 2025 interim final rule removed BOI reporting requirements for entities created in the United States and for their beneficial owners.

What are the dated CTA milestones?

• September 30, 2022: FinCEN published the BOI reporting rule, with a January 1, 2024 effective date.
• January 1, 2024: BOI reporting began under the original broad rule.
• November 30, 2023: FinCEN extended the initial deadline for companies created or registered in 2024 from 30 days to 90 days.
• December 3, 2024: a district-court injunction in Texas Top Cop Shop disrupted enforcement; the Fifth Circuit and Supreme Court later changed the posture.
• January 23, 2025: the Supreme Court stayed the Texas Top Cop Shop injunction.
• March 26, 2025: FinCEN's interim final rule narrowed the definition of reporting company to foreign reporting companies.

What changed before and after March 26, 2025?

Before: domestic and foreign reporting companies were generally in scope unless one of the CTA exemptions applied. After: domestic U.S.-created entities are exempt, and foreign companies registered in a U.S. state have 30 days to file after effective registration if no exemption applies.

What should a non-resident founder do with this?

If you formed a Delaware, Wyoming, New Mexico, or other U.S. LLC, the BOI obligation is currently removed. If you registered an existing non-U.S. company as a foreign entity in a U.S. state, read the foreign-company BOI status page and verify your facts against FinCEN before relying on any guide.

Sources and verification

Last verified: June 26, 2026

• FinCEN BOI main page
• FinCEN interim final rule Q&A
• Federal Register interim final rule, March 26, 2025
• Supreme Court stay order, January 23, 2025

Is this legal or tax advice?

非法律/税务/移民建议，以官方为准。