Status: FinCEN's final rule has been in force since August 14, 2026
Under a final rule from FinCEN, the Treasury bureau that collected beneficial ownership information (BOI) reports, companies created in the United States, and their owners, are exempt from federal BOI reporting. FinCEN announced the rule on August 11, 2026, and it took effect on August 14, 2026. The exemption covers LLCs, corporations and other entities created by filing with a U.S. state or tribe. An entity formed under the law of another country (not another U.S. state) and registered to do business in a U.S. state or tribal jurisdiction is still a reporting company unless another exemption applies. It files within 30 days after it receives notice that its state registration is effective, and it reports only non-U.S. persons who are beneficial owners or company applicants. The Corporate Transparency Act itself remains in the law; the exemption comes from FinCEN's rule, not a change to the statute. This area has changed several times since 2024. This section describes federal BOI reporting only, not state filings or other ownership-disclosure requirements.
General information about FinCEN's federal rule, not legal advice about any particular company. Last checked October 19, 2026 against FinCEN's beneficial ownership page and the Federal Register (91 FR 52508). Rules in this area have changed several times; fincen.gov/boi shows current status.
The short version: yes, the Corporate Transparency Act is still part of federal law. The exemption for companies created in the U.S. comes from FinCEN's rule, not from a change to the statute, and those are two different questions. For which entities are exempt and which are still reporting companies, see our BOI Reporting Hub. This page is the litigation and rulemaking timeline behind that hub.
The Timeline So Far
- 2021: The CTA becomes law as part of the Anti-Money Laundering Act of 2020, directing FinCEN to build a beneficial ownership reporting regime.
- January 1, 2024: FinCEN's original final rule takes effect. Under it, nearly every domestic and foreign LLC and corporation (absent an exemption) was required to report beneficial ownership information.
- Late 2024 – early 2025: Multiple federal district courts hear constitutional challenges. A nationwide injunction is issued, appealed, and stayed across several dockets (including Texas Top Cop Shop v. Garland and Smith v. U.S. Department of the Treasury), creating brief windows where enforcement was on, then off, then on again.
- March 26, 2025: FinCEN publishes an interim final rule that removes the BOI filing requirement entirely for U.S.-formed entities and U.S. persons, and narrows "reporting company" to mean only entities formed under foreign law that are registered to do business in a U.S. state or tribal jurisdiction. 90 Fed. Reg. 13688.
- August 11 to August 14, 2026: FinCEN announces its final rule on August 11, 2026. The rule adopts the March 2025 interim final rule as final, with certain limited changes. It is published in the Federal Register on August 14, 2026 (91 FR 52508) and takes effect that day. FinCEN has said it will delete the information that U.S. persons reported earlier, and we are not aware of a published completion date.
What Could Change This Picture
- FinCEN's rule. The exemption rests on FinCEN's own rule rather than on a change to the statute. The Federal Register notice records commenters who argued that the earlier interim rule departs from the text of the Corporate Transparency Act, and a later FinCEN rule could change the current one.
Because the rules in this area have changed several times, FinCEN's BOI page (fincen.gov/boi) shows the current status. Whether a particular entity is a reporting company, or fits another exemption, depends on its own facts and is a question for a licensed attorney or other qualified adviser.
General information about FinCEN's federal rule, not legal advice about any particular company. Last checked October 19, 2026 against FinCEN's beneficial ownership page and the Federal Register (91 FR 52508). Rules in this area have changed several times; fincen.gov/boi shows current status.
Where to Go Next
- BOI Reporting Hub: which entities are exempt and which are still reporting companies under FinCEN's final rule.
- Corporate Transparency Act (CTA) Definitive Guide — the full legal explainer: definitions, the original exemption categories, and the original 2024 rule.