BOI report 2026: do US LLCs still have to file?

What is a FinCEN BOI report?

BOI (beneficial ownership information) is information about a company's beneficial owners: the people who ultimately own or control it. FinCEN, the US Treasury's financial crimes enforcement bureau, writes the BOI reporting rules. A BOI report gives FinCEN those people's identifying details.

When the BOI rule was first published, most small US companies were expected to report. The rule has since changed. This post summarises FinCEN's official BOI page (accessed 12 October 2026). For short definitions, see our glossary in 30 seconds.

Why are US-formed companies exempt?

According to FinCEN's BOI page, US companies are exempt from the BOI reporting requirements and no longer have to file BOI reports. All entities created in the United States, and their beneficial owners, are exempt from reporting BOI. That includes an LLC formed in Wyoming or Delaware.

The page also gives the sequence of changes: FinCEN published an interim final rule on 26 March 2025, issued the final rule on 11 August 2026, and the final rule became effective on 14 August 2026. It notes that some older guidance on its site may be out of date and that guidance saying US companies must report should be disregarded.

Who still has to report BOI?

According to FinCEN's page, BOI reporting now applies only to entities formed under the law of a foreign country that have registered to do business in a US state or tribal jurisdiction. Those companies do not have to report beneficial owners who are US persons. What matters is where the company was formed, not where its owners live.

Is BOI a one-time or an annual report?

It was never a yearly filing. Under the original rule, a company filed one initial BOI report and then an updated report only when the reported details changed. Since FinCEN's rule change, companies formed in the United States do not file it at all, so there is no BOI date in a US LLC's yearly calendar.

What does this mean for your Wyoming or Delaware LLC?

A Wyoming or Delaware LLC is an entity created in the United States, and according to FinCEN's page it does not need to file a BOI report. If your company is connected to companies in other countries, assess your position across the whole structure with a qualified adviser. LaunchUS does not give legal or tax advice.

The BOI exemption does not remove the company's other obligations. The state annual report or tax, the Registered Agent renewal and federal forms filed with the IRS, such as Form 5472, continue, and they appear in your dashboard's compliance calendar. For a side-by-side of state annual obligations, see the table in Delaware for founders planning to raise.

Why are BOI payment requests suspicious?

FinCEN's page says filing BOI directly with FinCEN is free and that FinCEN does not send correspondence requesting payment for BOI. According to the page, FinCEN has no "Form 4022" or "Form 5102". Letters or emails using those names or asking for payment may be fraud attempts. FinCEN also warns about fake names that imitate official bodies.

Step by step: when you receive a BOI payment request

These steps help when a suspicious BOI letter or email arrives. The aim is to confirm from the official source whether a request is genuine before you pay anything. When in doubt, take your time and do not click links in the message; the steps below are meant to be followed in order.

1. Do not pay. FinCEN says it does not charge for BOI.
2. Check the sender. Compare the body name and form number with the warnings on FinCEN's page.
3. Open the official page yourself. Type fincen.gov into your browser; do not use links in the message.
4. Check your vault. Official state mail is received and scanned through the LaunchUS Registered Agent service and filed in your vault.
5. Ask us. For a letter you cannot match to anything in your vault, write to hello@launchus.app.
6. Ask your adviser. A qualified adviser can assess whether any legal or tax obligation applies.

Where does official mail arrive with LaunchUS?

Official mail the state sends your company arrives at the Registered Agent address. Our Registered Agent service receives it, scans it, files it in your vault and notifies you. The Registered Agent address is not a general business address or a verification address.

We form your company, and the formation document, EIN letter and official mail sit in one vault. Our LLC formation and EIN service pages explain who does what, and pricing shows which annual services are included. For general questions, see the US company FAQ.