Overview
The Corporate Transparency Act (“CTA”) remains federal law. However, FinCEN has issued an interim final rule that substantially narrows who must file Beneficial Ownership Information (“BOI”) reports.
As of August 4, 2026, most U.S.-formed entities (including Illinois corporations and LLCs) are not currently required to file BOI reports with FinCEN under FinCEN’s current interim rule.
Who is currently required to file BOI reports?
Under FinCEN’s current framework, BOI reporting generally applies to certain foreign entities, meaning entities that:
- are formed under the law of a foreign country, and
- have registered to do business in a U.S. state (or Tribal jurisdiction) by filing with a Secretary of State (or similar office), and
- do not qualify for an exemption.
Foreign reporting companies generally must report BOI for non-U.S.-person beneficial owners, but are not required to report beneficial owners who are U.S. persons under FinCEN’s current interim rule.
Summary of the current rule (high level)
| Topic | Current status (Aug 2026) |
| Domestic U.S. entities (formed in any U.S. state) | Currently not required to file BOI reports with FinCEN (no initial filing; no updates/corrections required under the interim rule). |
| U.S. persons as beneficial owners | Currently not required to be reported, including where they own/control an otherwise in-scope foreign reporting company. |
| Foreign entities registered to do business in the U.S. | May still be required to file, but generally only as to non-U.S.-person beneficial owners (unless an exemption applies). |
Current filing deadlines (for entities still in scope)
FinCEN’s current deadlines for foreign reporting companies are:
| Entity type | Current federal BOI deadline |
| Domestic U.S. companies | No current federal BOI filing, update, or correction deadline under FinCEN’s interim rule. |
| Foreign reporting companies registered before March 26, 2025 | BOI report was due April 25, 2025. |
| Foreign reporting companies registered on/after March 26, 2025 | BOI report due within 30 calendar days after registration becomes effective (or public notice of effectiveness). |
Foreign reporting companies that are in scope should also plan for updates if reportable information changes, consistent with the CTA’s reporting framework.
Penalties (willful violations)
The CTA’s penalty provisions remain in the statute. For willful violations, penalties have been described in updated sources as including:
- Daily civil penalties (inflation-adjusted above the prior $500/day figure; commonly referenced as approximately $591/day), and
- Criminal penalties of up to $10,000 and up to two years’ imprisonment.
Treasury/FinCEN have also stated that, under the current narrowed framework, they will not enforce BOI reporting penalties or fines against U.S. citizens, domestic reporting companies, or their beneficial owners.
Litigation and continued changes
The CTA has been subject to significant litigation. In December 2025, the U.S. Court of Appeals for the Eleventh Circuit upheld the CTA as constitutional. Additional legal developments and FinCEN’s ongoing rulemaking may further affect BOI reporting requirements going forward.
Practical guidance
- If your entity is a U.S.-formed corporation or LLC: Under current federal rules, you likely do not have a BOI filing obligation right now. Even so, it is prudent to maintain accurate ownership/control records for banking, transactions, licensing, and potential future changes.
- If your entity is formed outside the U.S. and registered to do business in the U.S.: You may still have a BOI filing obligation (focused on non-U.S.-person beneficial owners), and current deadlines may apply.
We can help
Piercey & Associates, Ltd. can assist in evaluating whether your entity is currently in scope under the CTA/FinCEN rules (including whether any exemption applies) and, where applicable, help with compliance planning.
Please contact us to begin the process and request a fee quote.
Advertising Material / Disclaimer:
This communication may be considered Advertising Material. This communication does not establish an attorney-client relationship even if we have represented you in the past. The information contained in this communication is intended for general information purposes only and should not be applied to your specific facts and circumstances without consultation with competent legal counsel and/or another retained professional advisor. If you fail to contact us to retain our services, we will not take any further action on this issue and will presume you are handling the full responsibilities as detailed in this communication. This August 2026 update is intended to replace and supersede our prior July 2024 website post regarding FinCEN BOI reporting.