How to File a BOIR in 2026 (Foreign Reporting Companies): Step-by-Step

Current status (as of June 2026). FinCEN‘s March 26, 2025 interim final rule narrowed “reporting company” to foreign entities only. Every entity formed in the United States — and every US person — is now exempt from BOI reporting, and enforcement against domestic companies is suspended. The CTA statute was upheld (11th Circuit, December 16, 2025) and a final rule is still pending. This guide is for the one group that still files: foreign reporting companies.

Here’s the honest version most “how to file a BOIR” guides won’t tell you: if you formed an LLC or corporation in a US state, you almost certainly don’t have to file anything. The mandate was rolled back in March 2025, and most top-ranking walkthroughs never updated. This guide is for foreign reporting companies — and it covers the foreign-entity specifics the generic guides skip.

Are you even required to file? (a 30-second self-check)

Only a foreign reporting company still files — an entity formed under the law of a foreign country that registered to do business in a US state.

Formed in a US state? (a Delaware LLC, a Wyoming corp) → exempt. Nothing to file. Stop here.
Formed in another country and registered in a US state? → foreign reporting company. Keep reading.

One trap: a foreign-owned US company is not a foreign company. If you’re a non-US person who owns a US LLC, that LLC was still formed in the US — so it’s exempt. The exemption is about where the entity was formed, not who owns it.

What you’ll need before you start

The online BOIR cannot be saved midway — gather everything first:

Full legal name + any DBAs
Country of formation
US state of first registration
A current US address
Your foreign tax ID + issuing jurisdiction (or a US TIN/EIN if held)
For each beneficial owner: name, DOB, address, and an ID image (max 4MB; JPG/PNG/PDF)

How to file your BOIR on the FinCEN portal (step-by-step)

Confirm you’re a foreign reporting company. If you’re US-formed, you’re exempt — don’t file.
Open the FinCEN BOI e-filing portal at boiefiling.fincen.gov. Use the online webform or the PDF. FinCEN also publishes a step-by-step instructions PDF.
Reporting Company tab: enter legal name + DBAs. The optional FinCEN ID is item 3.
Set Tax ID type to “Foreign.” This enables the Country/Jurisdiction field (item 9) for your foreign tax ID.
Foreign-formation fields: enter country of formation (item 10a) → then “State of first registration.”
Current US address (items 11-15) — still required.
Beneficial owners — apply the no-US-persons rule. You do not report beneficial owners who are US persons. Upload an acceptable ID image (4MB max) for each owner you do report.
Review and submit. Save the confirmation (your FinCEN ID, if requested, is returned here).

Deadlines for foreign reporting companies

Registered before March 26, 2025 → due April 25, 2025.
Registered on or after March 26, 2025 → 30 days from the effective notice of registration.

It’s not annual, but if reported information changes, file an updated or corrected report.

It’s free — paid letters are a scam

Filing your BOIR directly with FinCEN costs $0. Any letter or email demanding payment, or referencing a fake “Form 4022,” is a scam. FinCEN never charges a fee to file.

Penalties (and who they actually apply to)

For entities that still file, the penalties are real: civil of roughly $591/day, criminal up to $10,000 and/or 2 years for willful violations. They are not enforced against domestic companies (which are exempt) — they’re relevant to foreign reporting companies.

Frequently asked questions

Do foreign reporting companies still have to file in 2026?

Yes — they’re the only entities still required to file.

Are US/domestic companies still required to file?

No. All US-formed entities and US persons are exempt; enforcement against domestic companies is suspended.

Do I report US persons as beneficial owners?

No. US persons are exempt, so a foreign reporting company reports only its non-US owners.

What is a FinCEN ID, and is it required?

A unique identifier you can request when filing (item 3). It’s optional; it’s returned in your confirmation.

Is filing free? Why do services charge?

Filing with FinCEN is free; services charge for convenience. Any letter demanding a government fee is a scam.

Do I file every year?

No — file once, then only to update or correct information.

Is the domestic exemption permanent?

It comes from an interim rule, with a final rule still pending. The CTA statute was upheld. Follow the rule in effect.

The bottom line

If your company was formed in a US state, you’re done — nothing to file. If you’re a foreign reporting company, the walkthrough above gets you filed for free, with the foreign-entity fields and no-US-persons rule handled. If you’d rather not deal with the portal, our team files BOIRs for foreign reporting companies for a flat $99 — but the government fee is $0, so only pay for the convenience if it’s worth it to you.

Sources

Last reviewed June 2026. Not legal advice.