Department of Treasury Not Enforcing BOI Reporting Requirements Under the CTA

The Corporate Transparency Act (CTA), administered by the Financial Crimes Enforcement Network (FinCEN), requires certain business entities to report beneficial ownership information (BOI) to the federal government. Recent litigation and regulatory action have significantly narrowed the scope of required reporting and have—for now—exempted U.S.-based entities from the requirement.

As of March 26, 2025, FinCEN’s interim final rule exempts all domestic entities and U.S. persons from BOI reporting. Reporting obligations now apply only to entities formed under foreign law and registered to do business in the United States, and FinCEN announced it will not attempt to enforce the rule against domestic entities while the interim rule is in place. Foreign reporting companies registered prior to March 26, 2025, must file their initial BOI reports by April 25, 2025. Foreign entities registering on or after March 26, 2025, must file within 30 calendar days of registration.

FinCEN continues to consider public comment on the interim rule and is expected to finalize the rule later in 2025. Given the evolving legal and regulatory landscape, businesses should continue to monitor BOI-related developments closely. CTA supporters in the Senate, for example, have criticized FinCEN’s scaling back of the BOI reporting requirements. For now, however—and, it appears, for the foreseeable future—there are no BOI reporting requirements for domestic entities.