FinCEN BOI Final Rule Q&A #7
Who is a beneficial owner of a reporting company?
Cite as FinCEN BOI Final Rule Q&A #7 (August 11, 2026 final rule)
A beneficial owner is an individual who either directly or indirectly: (1) exercises substantial
control over the reporting company, or (2) owns or controls at least 25% of the reporting
company’s ownership interests. Because beneficial owners must be individuals (i.e., natural
persons), trusts, corporations, or other legal entities are not considered to be beneficial
owners. However, in specific circumstances, information about an entity may be reported in
lieu of information about a beneficial owner.
Please note that reporting companies are not required to report the BOI of any U.S. persons
who are beneficial owners or company applicants. Furthermore, U.S. persons are exempt
from having to provide BOI to any reporting company for which they are beneficial owners
or company applicants.