By Jack Polales

On August 14, 2026, FinCEN adopted its Interim Final Rule (“IFR”) on Beneficial Ownership Information Reporting (“BOIR”), which had been in place since March 26, 2025. Two pivotal provisions of the IFR are now final. First, domestic reporting companies, and by extension the owners of those companies, are exempted from all reporting requirements. The Final Rule also expands on the IFR in that U.S. persons will not be required to update or correct information previously provided to FinCEN. The second major provision adopted is that U.S. persons who are beneficial owners of foreign reporting companies are now exempted from reporting requirements, with the addition to the IFR that U.S. person company applicants are also exempted. Additionally, the Final Rule notes a directive that FinCEN will work with the National Archives and Records Administration to implement a process to delete U.S. person information previously obtained in filed BOI reports.

In essence, all that remains of the Corporate Transparency Act’s Beneficial Ownership Information Reporting is that foreign entities are required to report personal information for foreign persons that are beneficial owners of said entities.

It is evident that this rule marks a division along political party lines, and as such could see a revival as political winds shift. For now however, U.S. business owners large and small can breathe a sigh of relief that they no longer need to report detailed personal identifying information to FinCEN under threat of criminal penalties.

1 “On January 20, 2025, there was a change in presidential administrations, which resulted in a reassessment of the balance struck by the Reporting Rule.” Final Rule, Beneficial Ownership Information Reporting Requirement Revision: Supplemental Information, available at https://www.federalregister.gov/d/2026-16576/p-45