What Information Is Required for a BOI Report? (2026 Update: Foreign Reporting Companies Only)

Current status (as of June 2026): Under FinCEN‘s interim final rule of March 26, 2025, only foreign reporting companies have to file a Beneficial Ownership Information report (BOIR). Companies formed in the United States — and US persons generally — are exempt, and enforcement against domestic companies has been suspended. The old January 1, 2025 deadline and the $591-per-day penalty you may have read about no longer apply to US-formed entities. This is an interim rule; a final rule is still pending, and the underlying statute has been upheld in court.

So if you own a US LLC or corporation, here’s the honest version: you almost certainly don’t need to file anything, and you can stop worrying about the field checklists that filled the internet in 2024. The information requirements below still matter — but only for the businesses that genuinely still file. If that’s you (a company formed outside the US and registered to do business here), this page is your exact-fields checklist. If it isn’t, read the first section, exhale, and move on.

Who actually has to file a BOI report in 2026

For most of 2024, the message everywhere was “tens of millions of US businesses must file by January 1, 2025, or face penalties.” That message is out of date. On March 26, 2025, FinCEN issued an interim final rule that narrowed the reporting requirement to foreign reporting companies only — entities formed under the law of a foreign country and registered to do business in a US state or Tribal jurisdiction.

Two practical consequences follow:

• US-formed entities are exempt. If your LLC or corporation was created by filing with a US state or Tribal office, you are not a reporting company under the current rule, and FinCEN has suspended enforcement against domestic companies.
• US persons are exempt as individuals. Even when a foreign company does file, US-person owners are not reported (more on that carve-out below).

The widely-cited $591-per-day civil penalty and the January 1, 2025 deadline were tied to the original, broad rule. Neither applies to US-formed entities anymore. Plenty of older articles, videos, and competitor pages still repeat them — treat those as outdated.

One caveat worth stating plainly: this is an interim final rule. A final rule is still pending, and the statute behind it (the Corporate Transparency Act) has been upheld. Scope could change again. The current, dated status is what’s written above.

Do LLCs have to file a BOI report?

Most don’t. A US-formed LLC is exempt under the current rule. An LLC only files if it was formed in a foreign country and then registered to do business in the US — and even then, only if it doesn’t qualify for one of FinCEN’s exemptions.

The information a foreign reporting company must report

If you are a foreign reporting company, a BOIR collects up to four sets of information: details about the company itself, details about each beneficial owner, details about a company applicant (only for newer registrations), and an optional FinCEN ID that can stand in for an individual’s personal details. Here’s the full picture in one place.

Category	Information required
Reporting company	Full legal name; any trade or DBA name; current US address; the State or Tribal jurisdiction where it first registered; and its IRS Taxpayer Identification Number (TIN/EIN) — or, if it has none, a foreign tax ID plus the issuing jurisdiction.
Beneficial owner	Four pieces for each owner: full legal name; date of birth; residential address; and a unique ID number plus issuing jurisdiction from an acceptable document — together with an image of that document. US-person owners are not reported.
Company applicant	Required only for reporting companies registered on or after January 1, 2024. Up to two applicants, each with the same four pieces of information plus a document image.
FinCEN ID	Optional. A 12-digit identifier an individual or company can obtain and supply in place of the personal information above.

The no-US-persons carve-out: which owners actually go on the form

This is the part nearly every other page skips. Once you know that only foreign reporting companies file, the next real question is which owners do you list — and the answer is not “all of them.”

A beneficial owner is any individual who either owns or controls at least 25% of the company, or exercises substantial control over it (for example, a senior officer or someone with authority over important decisions). Normally you’d report each such person’s four pieces of information.

But under the current rule, a foreign reporting company does not report beneficial owners who are US persons. If an owner is a US citizen or US resident, they’re left off the report — even if they hold a controlling stake. You report only the company’s non-US beneficial owners.

The practical edge case: if every beneficial owner of the foreign company happens to be a US person, there may be no individual owner information to report at all. The company still exists as a foreign reporting company, but the carve-out removes its US-person owners from the form. When in doubt about who qualifies, FinCEN’s BOI FAQs walk through the definitions in detail.

The four pieces required for each beneficial owner

For every non-US beneficial owner you do report, the form asks for exactly four things:

1. Full legal name
2. Date of birth
3. Residential address — a home address, not a business or registered-agent address
4. A unique ID number and its issuing jurisdiction, taken from an acceptable identification document

Acceptable identification documents

The unique ID number has to come from one of these:

• A non-expired US state driver’s license
• A non-expired ID document issued by a US state, local government, or Tribe
• A non-expired US passport
• A non-expired foreign passport (the common choice for non-US owners)

ID image specifications

You also upload an image of that same document. The file must be a JPG, PNG, or PDF, and no larger than 4 MB. Make sure the image is clear and legible — the ID number and jurisdiction need to be readable. The exact item-by-item requirements are spelled out in FinCEN’s BOIR Filing Instructions.

Company applicant information

Company applicant details are only required if the reporting company was created or registered on or after January 1, 2024. Companies that registered before that date don’t report applicants at all.

When they’re required, you can list up to two company applicants: the individual who directly filed the registration document, and the individual who was primarily responsible for directing that filing. Each applicant needs the same four pieces of information as a beneficial owner — name, date of birth, address, and a unique ID number with jurisdiction — plus an image of the identification document.

The FinCEN ID option

A FinCEN ID is an optional 12-digit number that an individual (or a company) can request from FinCEN. Once someone has one, they can supply the FinCEN ID on a report in place of their personal information. It’s handy for a person who shows up on more than one filing — they hand over a single number instead of re-entering name, date of birth, address, and ID details each time. It’s entirely optional; you can always provide the underlying information directly.

How and when to file

Filing is free. Reports are submitted electronically through FinCEN’s BOI E-Filing System — there’s no government fee. A BOIR is a one-time report, not an annual renewal; after the initial filing you only submit an update or correction if reported information changes or was wrong.

Under the March 2025 interim final rule, the deadlines for foreign reporting companies are:

• Foreign companies registered to do business in the US before March 26, 2025 had until April 25, 2025 to file.
• Foreign companies registered on or after March 26, 2025 have 30 days from registration to file.

You can confirm the current deadlines and scope on the official FinCEN BOI hub.

Frequently asked questions

Sources

• FinCEN — Beneficial Ownership Information hub
• FinCEN — Removes BOI reporting requirements for US companies and US persons (news release)
• FinCEN — Interim final rule Q&A
• FinCEN — BOI FAQs (field-level)
• FinCEN — BOIR Filing Instructions (PDF)
• US Treasury — Press release sb0060
• Federal Register — Interim final rule (March 26, 2025)

If you’re a foreign reporting company, we can file it for you

If you’ve read this far and you genuinely fall in scope — a company formed abroad and registered to do business in the US — gathering the fields, formatting the ID images, and submitting the BOIR correctly is the kind of task that’s easy to get slightly wrong. Our done-for-you BOIR filing handles the whole form for a flat $99. And if you’re a US-formed company, you don’t need us for this at all: you’re exempt, and we’d rather tell you that than sell you something you don’t need.