Updated October 2026. This article replaces our earlier coverage of BOI reporting, first published in November 2023, and our 2025 piece on state and federal reporting.
What is the Corporate Transparency Act?
The Corporate Transparency Act (CTA) became law on 1 January 2021 as part of the Anti-Money Laundering Act of 2020. It aimed to stop anonymous shell companies being used to hide money, partly in response to the Panama Papers. The CTA asked many corporations, LLCs and similar entities to report their beneficial owners to the Financial Crimes Enforcement Network (FinCEN), the US Treasury bureau that fights financial crime.
FinCEN's original rule took effect on 1 January 2024. For a time, it meant most small US entities, including many family office LLCs and holding companies, had to file.
What changed in 2025 and 2026?
After a run of court challenges and paused deadlines, FinCEN changed course.
- 26 March 2025: interim final rule. FinCEN removed all US-formed entities from the definition of "reporting company". US companies no longer had to file initial BOI reports, or update or correct ones already filed. Foreign companies registered in the US still had to report, but not their US owners.
- 14 August 2026: final rule. FinCEN adopted the interim rule as final, with some limited changes. US companies stay exempt. Reporting companies no longer report US company applicants, and US persons no longer need to update a FinCEN ID. FinCEN also said it will delete BOI that US persons reported before they became exempt.
The exemption comes from a power in the CTA itself. It lets Treasury exempt classes of entities when collecting their information would not serve the public interest. The law has not been repealed, so a future administration could revisit the rule.
Does a family office still have to file?
For most US family offices, no. If your family office, holding companies, LLCs and investment vehicles were formed in the US, they are not reporting companies and have nothing to file with FinCEN.
Look more closely if your structure includes:
- Foreign entities registered to do business in a US state. A non-US company or fund that has filed to do business in the US is still a reporting company. It must report its non-US beneficial owners and file within 30 days of registering.
- Foreign pooled investment vehicles. A non-US fund registered to do business in the US may still need to file a short report naming the individual who exercises substantial control over it. Check this with the fund's administrator or counsel.
- Foreign family members as owners. In a foreign reporting company, non-US beneficial owners must still be reported. US persons are excluded, both as owners and as company applicants.
If your family office filed BOI reports in 2024 or early 2025, you do not need to update or withdraw them. FinCEN has said it will delete information previously reported by US persons who are now exempt.
What should family offices still do?
- Keep a clear ownership map. Banks, custodians and fund administrators still ask who owns and controls each entity under their own know-your-customer rules.
- Check state rules. Federal and state reporting are separate. Some states have proposed or passed their own ownership disclosure rules, and these are not affected by FinCEN's exemption. Confirm the position in each state where you form or register entities.
- Keep your filing records. Hold on to copies of any past BOI filings, FinCEN IDs and the ownership documents behind them. They are useful evidence for banks and for any future change in the rules.
- Brief your service providers. Make sure your corporate secretary, registered agent or compliance provider is no longer filing or renewing BOI work for US entities on your behalf.
- Review any foreign entities. Make sure non-US companies registered in the US have filed, and that filings are kept up to date. If you hold entities in several countries, our piece on why tax residency matters to family office operations covers the wider picture.
- Watch for change. The exemption is a regulation, not a change to the statute. Ask your advisers to flag any new rulemaking.
Bottom line
For most US family offices, federal BOI reporting is over. The work that remains is ordinary good governance: knowing who owns and controls each entity, and being ready to show it to banks, regulators and counterparties. For more on setting that up, see what good governance looks like inside a single family office, or explore our United States family office hub.
This article is for general information and is not legal advice. Speak to a qualified adviser about your own structure.
Sources
- FinCEN, Beneficial Ownership Information Reporting Requirement Revision, final rule, 91 FR 52508 (14 August 2026)
- FinCEN, Beneficial Ownership Information Reporting Requirement Revision and Deadline Extension, interim final rule, 90 FR 13688 (26 March 2025)
- FinCEN news release, 11 August 2026
- FinCEN BOI FAQs
