FinCEN BOI Final Rule Q&A #3
Who is still required to report BOI under the final rule?
Cite as FinCEN BOI Final Rule Q&A #3 (August 11, 2026 final rule)
“Reporting companies” under the revised reporting requirements include only those entities
that are formed under the law of a foreign country and have registered to do business in any
U.S. State or Tribal jurisdiction by the filing of a document with a secretary of state or
similar office.
There are multiple types of entities that are exempt from the reporting requirements. Foreign
entities potentially falling under the definition of “reporting company” should carefully
review the qualifying criteria before concluding whether the foreign company must report
BOI.