Is the BOI report still required? What changed in 2025

The direct answer

No. Companies formed inside the United States — including the LLC you set up as a non-resident — are no longer required to report beneficial ownership information to FinCEN.

FinCEN issued an interim final rule in March 2025 exempting US-formed entities and US persons from the requirement, and it remains in force.

So why does everything you read say otherwise?

Because the obligation was real, and very widely written about, right up until it was not. The Corporate Transparency Act put millions of US entities under a reporting duty, and an enormous amount of guidance was published through 2024 and early 2025. Then the position changed, and most of that guidance did not.

This is a general hazard with legal content online. The practical rule: any article about BOI that does not mention March 2025 is out of date, however recently it appears to have been posted.

Who still has to report

The obligation was narrowed, not abolished. It still applies to companies formed outside the United States that register to do business in a US state — foreign reporting companies.

The distinction in practice:

• You formed an LLC in Wyoming while living in Cairo → a US company → exempt from federal BOI.
• You have a company registered in Dubai and registered it to do business in Florida → a foreign registered company → still reporting.

What decides it is where the entity was formed, not the owner's nationality. That trips people up: a foreign owner does not make the company foreign.

The obligation moved rather than vanished

The exemption is federal only. With the federal government stepping back, several states began operating beneficial-ownership registers of their own — filed with the state rather than with FinCEN, each with its own deadlines, fees and penalties.

So the question is no longer "do I have to file BOI?" but "what does my state require this year?" — and the answer differs by state, and can change within a year.

What this means for your annual checklist

If you formed a US LLC as a non-resident, the obligations that remain on you are the ones that were always the real ones:

• The state annual report — filed with the state you formed in, on its own schedule, with its own fee. Some states do not require one at all.
• The franchise tax, where the state levies one — Delaware does, Wyoming and New Mexico do not.
• The federal tax return, which for a single-member LLC with a foreign owner usually means Form 5472 attached to a pro-forma 1120. That one has a $25,000 penalty and has not changed.
• Registered agent renewal — not a filing, but a lapse here can put the company out of good standing just as surely as a missed report.

Notice what the BOI change did and did not do. It removed one federal filing. It removed none of the above, and the one with the largest penalty attached is still there. A founder who reads "BOI is gone" and concludes there is nothing left to file has swapped one wrong belief for another.

What if you already filed?

Nothing is required of you. Information submitted before the exemption does not create an ongoing update duty while you sit in the exempt category. And if you never filed and the old deadline passed, the exemption removed the obligation that penalty would have rested on.

How to check for yourself

Do not rely on an article — including this one. The only authoritative source is FinCEN's own page at fincen.gov/boi. For state-level duties, it is the Secretary of State website for the state you formed in.

The rule we work to internally: any obligation we put in a client's calendar has to trace to a current official source, not to a blog post.

What we do about it

We removed the federal BOI filing from the obligations we show clients with US-formed companies, and kept state-level beneficial-ownership tracking inside the compliance service. If your company was formed outside the US and registered to do business inside it, the federal obligation does still apply to you, and we track it with you.

A caution

This is general information, and this particular area has changed more than once in a short period and may change again. Verify against the official source before acting on it, or ask a professional about your own situation.