Do LLCs still file a BOI report with FinCEN?

This post is part of our business setup hub. It answers one question for freelancers with an LLC: do you still owe FinCEN a beneficial ownership information (BOI) report? The facts below come from FinCEN and the Federal Register and were checked on October 23, 2026.

What a BOI report was

The Corporate Transparency Act asked most small companies, LLCs included, to tell FinCEN (the Treasury's Financial Crimes Enforcement Network) who owned or controlled them: names, addresses, birth dates and an ID document for each beneficial owner. Reporting started January 1, 2024, and FinCEN never charged a fee to file. Freelancers with one-person LLCs were in scope, and FinCEN's own release describes the 2026 final rule as ending the requirement for millions of small business owners.

What changed, with dates

The final rule doesn't add any new obligation. The Federal Register notice says it extends the interim rule's exemption on reporting US person information, which is why it took effect the day it was published. Some older pages and third-party articles still show the old deadlines; rely on the final rule and the current fincen.gov/boi page instead.

Who still has to file

• Domestic companies, meaning any corporation or LLC created by filing with a US state or tribal office: no report and no updates. This is where nearly every freelancer's LLC sits, whether it was formed in your home state, Delaware or Wyoming.
• Foreign companies, meaning entities formed under another country's law that registered to do business in a US state or tribal jurisdiction: still reporting companies, unless an exemption applies. They report only beneficial owners who are not US persons.
• US persons who already filed or hold a FinCEN ID: nothing to update or correct.

A freelancer who lives abroad and formed a US LLC through a formation service still has a domestic company, because the LLC was created by a US state filing. The owner's residence doesn't change that. Other US filings may still apply to that LLC, so check with an accountant who works with foreign owners.

Forming a new LLC after August 2026

A new LLC formed with any US state after the final rule has nothing to file with FinCEN, now or later. If a formation checkout or a compliance package offers a BOI filing for a US LLC, you can leave it out. What a new LLC still owes depends on the state: the formation fee, often an annual or biennial report, sometimes a franchise tax, and a registered agent. Those are where the real yearly cost of an LLC sits.

What to do now

1. If you formed your LLC in the US, stop tracking BOI deadlines. There's nothing to file or update with FinCEN.
2. Be wary of letters, emails or paid services that say you must file or update a BOI report for a US company. Filing with FinCEN was always free, and US companies are now exempt.
3. Keep your state filings current. Your Secretary of State's annual or biennial report, franchise tax and registered agent are separate from FinCEN and still apply. Some states may have their own disclosure rules, so check your state's business filing office.
4. Keep the date of your next state filing where you'll see it. A recurring card on a board works; you can keep notes and Kanban boards for this kind of reminder.

If you're still deciding whether to form an LLC at all, the BOI report is no longer part of the cost. Our 30-day checklist for starting a freelance business lists the setup steps that do apply, and the W-9 guide shows how an LLC fills out the form clients ask for.

This is general information about a federal rule as of October 23, 2026, not legal advice. Rules can change again; check fincen.gov/boi before relying on it, and ask a business attorney or CPA about your own company, especially if it was formed outside the US.