BOI reporting in 2026 - the requirement that (mostly) disappeared
If you researched US LLCs in 2024, you read scary articles about the Corporate Transparency Act's beneficial ownership (BOI) reports - with fines and even prison for non-filing. That world changed on March 26, 2025, and a lot of content on the internet has not caught up.
The current rule, in one paragraph
Under FinCEN's interim final rule of March 26, 2025, all entities created in the United States are exempt from BOI reporting - and that includes a Wyoming or New Mexico LLC owned entirely by a non-US person. The exemption is defined by where the entity was formed, not by who owns it. Only entities formed under foreign law that register to do business in a US state remain reporting companies. In short: form a US LLC, and as of today there is no federal BOI report to file.
Why you should keep half an eye on it anyway
This exemption rests on an interim final rule. FinCEN said it would finalize the rule in 2025 and missed that target; a final rule has been under review at OMB since mid-2026, and there is pending litigation and legislation around the Corporate Transparency Act. A future final rule, court decision, or statute could reinstate obligations - possibly with deadlines measured in weeks. This page carries a verification date for exactly that reason.
What we recommend
- Don't pay anyone for "BOI filing" on a US-formed LLC today - there is currently nothing to file federally.
- If you use a registered agent service, their compliance alerts are an easy way to hear about changes; FinCEN's own BOI page is the authoritative source.
- Note that a few states are building their own transparency regimes (New York's LLC Transparency Act, for example). None of the five states we compare had an equivalent requirement in force for non-resident LLCs as of our verification date - but this is the kind of fact you re-check yearly.