Do You Need to Update Your BOIR in 2026? (Foreign Companies Must — Most U.S. Owners Don’t)

Current status (as of June 2026): Only foreign reporting companies still have to update their BOIR — and they have to do it within 30 days of a change. If you formed your company in the United States, you’re exempt. You don’t need to update or correct a report you already filed, even if your information has changed since.

That answer comes straight from the FinCEN interim final rule issued on March 26, 2025, which removed beneficial ownership reporting for US-formed companies and US persons. Enforcement against domestic entities is suspended, and a final rule is still pending — but as the rule stands today, the update duty lives only with foreign filers.

Most people who land here are in one of three situations. You filed a BOIR in 2024 or 2025 and something changed, and you want to know if you owe an update. You’re a foreign reporting company and you genuinely still have a 30-day clock to manage. Or you filed by mistake and want the report gone. This guide handles all three, plainly.

The 10-second answer: which branch are you on?

Almost everyone splits into one of two paths. Find yours and you can stop reading once your question is answered.

Branch 1 — You formed your company in the US. You’re exempt. You didn’t have to file an initial report, you don’t have to update one, and you don’t have to correct one — even if your address, your owners, or your ID details changed since you filed. There is nothing for you to do. If you already filed before the rule changed, that report simply sits where it is.

Branch 2 — You’re a foreign reporting company. That means your company was formed outside the United States and then registered to do business in a US state. You’re still inside the rule. If your reported information changes, you must file an updated report within 30 days of the change.

If you’re on Branch 1, the rest of this article is mostly reassurance and a couple of myths worth killing. If you’re on Branch 2, skip ahead to the update triggers — that’s the part you need.

“I already filed in 2024 — am I done?”

If you formed your company in the US: yes. You’re done.

The report you filed back in 2024 or early 2025 doesn’t need to be refreshed, renewed, or touched again. After the March 2025 interim final rule, US-formed entities “do not need to file initial reports, and do not need to update or correct” prior reports — even if the information in them has since changed. So a new address, a new manager, a member who left — none of it triggers an obligation for you.

This is also where a stubborn myth needs to die: BOI was never an annual filing. It was always event-driven — you filed, and then you only acted again if something changed. For domestic entities, there are now no events that require action. There’s no yearly form, no renewal, no anniversary date to watch.

And you don’t need to file anything to tell FinCEN that your domestic entity is now exempt. There’s no “we’re exempt now” notice to submit — you simply stop. (Law firm Verrill makes this point directly: there’s no need to report that your domestic entity is now exempt.)

If you’re a foreign reporting company: what triggers an update

This section is for Branch 2 — companies formed abroad and registered to do business in a US state. One thing to know up front: foreign companies don’t report their US-person owners. But for the owners and details you do report, changes still have to be filed.

You file an updated report within 30 days when any of the following happens:

Change	Example
New or removed beneficial owner	An owner is added, or someone exits the ownership/control structure
Owner name, address, or ID-number change	A beneficial owner moves, marries and changes their name, or gets a new ID number
New identifying document	An owner’s passport or license is reissued — attach the new document image
Company jurisdiction change	The company’s formation or registration jurisdiction changes

The deadline is firm: within 30 days of the change. For foreign filers who miss it, penalties can run to roughly $591 per day. That’s not a scare tactic — it’s just the number, and it’s the reason the 30-day clock matters.

Updated report vs. corrected report (don’t mix these up)

FinCEN treats two situations differently, and filing the wrong one causes problems. The distinction is simple once you see it:

Updated report — for information that changed after you filed. It was correct when you submitted it; reality moved.
Corrected report — for information that was wrong when you filed it. It was a mistake from the start.

Here’s where people slip. Say your LLC’s name change is still working its way through the IRS and you’re not sure whether to “update” or “correct.” If the name genuinely changed, that’s an update. If you typed the wrong name originally, that’s a correction. Picking the wrong report type is a real, common error — so match the report to what actually happened.

The deadlines mirror the definitions: file an update within 30 days of the change, and file a correction within 30 days of becoming aware of the error.

The 90-day correction safe harbor

There’s built-in breathing room for honest mistakes. A foreign filer who corrects an inaccurate report within 90 days of the original deadline avoids the penalty. It’s not a loophole to lean on — it’s a grace window so a good-faith error caught a little late doesn’t turn into a daily fine.

Can I delete or withdraw a BOIR?

No — there’s no delete button. FinCEN has no process to delete or withdraw a filed BOIR. The only two actions that exist are Update and Correct. A report you filed can’t be unfiled.

If you filed by mistake — say you’re a US-formed single-member LLC who filed before the rule changed and now wishes you hadn’t — there’s nothing to undo, and nothing you need to undo. You’re exempt, the old report just sits there, and you take no further action.

Don’t pay for an “annual update” subscription you don’t owe

This is the part worth being blunt about. Some services are selling domestic owners ongoing “update,” “monitoring,” or “annual compliance” subscriptions — for a duty that no longer exists. If you formed your company in the US, you owe nothing on a recurring basis: no annual fee, no monitoring retainer, no “we’ll keep your BOIR current” plan. There’s nothing to keep current.

The only people who should be paying for a BOIR filing at all are foreign reporting companies that still have to file. Everyone else: keep your money.

Is this permanent?

Worth being honest here too. The March 2025 rule is an interim final rule, and a final rule is still pending. But the direction is steady: in December 2025 the 11th Circuit upheld the Corporate Transparency Act, and the IFR exemption stands. In April 2026, a House panel backed repealing domestic reporting altogether (as reported by the Journal of Accountancy). Nothing is carved in stone, but everything currently points toward the exemption holding.

Frequently asked questions

Do domestic companies still update their BOIR after March 2025?

No. US-formed entities are exempt and don’t need to update or correct a prior report, even if their information changed.

Do I file BOI every year?

No. BOI was never an annual filing — it’s event-driven. For domestic entities there are now no events that require any action.

What changes trigger a BOI update?

For foreign reporting companies: a new or removed beneficial owner; an owner’s name, address, or ID-number change; a new identifying document (attach the new image); or a change in the company’s jurisdiction.

What’s the difference between an updated and a corrected report?

An updated report covers information that changed after filing. A corrected report fixes information that was wrong when you filed. Update within 30 days of the change; correct within 30 days of noticing the error.

Can I delete or withdraw a filed BOIR?

No. There’s no deletion or withdrawal process. The only available actions are Update and Correct.

Do foreign-owned US companies have to update?

The obligation follows where the company was formed. Foreign reporting companies — formed abroad and registered in a US state — must update within 30 days of a change. Foreign companies don’t report their US-person owners.

Is BOI still required in 2026?

Only for foreign reporting companies. US-formed entities and US persons are exempt under the March 26, 2025 interim final rule.

The bottom line

Two branches, one breath: if you formed your company in the US, you don’t need to update or correct anything — you’re done. If you’re a foreign reporting company, file your update within 30 days of any change.

If you’re a foreign reporting company and you’d rather hand the update off than wrestle the form, that’s exactly what our flat $99 BOIR filing service is for. And if you’re a US-formed owner who just wanted to be sure — you’re all set. Nothing to file, nothing to pay.