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Katz & Associates / Corrected BOI guidance
Do not act on the old January 13, 2025 deadline. Start with where the company was formed, not an outdated filing reminder.
A correction to our earlier article
Companies created under U.S. law do not have to file beneficial ownership information (BOI) reports with FinCEN. The current rule exempts them from this Corporate Transparency Act duty. The January 13, 2025 deadline discussed in the earlier version of this page is not a current filing deadline for those companies.
The final rule was announced August 11, 2026 and took effect August 14, 2026. Treasury’s announcement confirms the exemption is permanent under that rule, not just a temporary pause in enforcement. This article keeps the old web address so readers following earlier links can find the correction.
A formation-record check
This decision aid separates an exempt U.S.-created entity from a foreign-country entity that may need closer review. It does not decide every company’s filing duty.
| What the records show | What to do next |
|---|---|
| Created under Florida or another U.S. jurisdiction's law | The domestic-company BOI exemption applies. Do not treat an old filing reminder as proof that a report is due. |
| Created under a foreign country's law | Check whether it registered through a qualifying filing with a U.S. state or Tribal office, then check whether an exemption applies. |
| Only a trade name, Florida registration, or bank record is available | Find the formation records. A trade-name, registration, or bank record alone may not establish the country of creation. |
| The group has more than one legal entity | Check each legal entity separately rather than assuming one conclusion covers the whole group. |
An original records-review aid based on the current rule. See FinCEN’s final-rule questions and answers for the reporting-company definition and exemptions.
One word, two different uses
For example, suppose an LLC is formed in Delaware and later registers to do business in Florida. Florida may describe it as a foreign LLC because it was formed outside Florida. That does not mean it was formed in a foreign country.
By contrast, an entity formed under another country’s law that registers through a qualifying U.S. filing may fall within the reporting-company definition. Other exemptions may still apply. Do not jump from “formed abroad” to “must file” without checking both the registration and exemption rules.
The published final rule controls that review. A business with cross-border ownership or unclear formation records should get advice about its own facts, including any deadlines that actually apply. This page does not set one new deadline for all foreign companies.
Company records and personal records are different
The final rule also exempts U.S. persons’ information from BOI reporting. This includes U.S. beneficial owners and company applicants. Company applicants are the direct filer and, when more than one person is involved, the person chiefly directing or controlling the filing. That does not mean every owner or employee. Check the current rule before asking for ID records.
The earlier version of this article also used an inaccurate personal-information checklist. When reporting a person’s identifying information directly, the required ID number and image cannot be replaced with a Social Security number. A permitted FinCEN identifier may be used instead of personal information where the rules allow. FinCEN’s identification guidance lists accepted unexpired documents, including a foreign passport when the person lacks the listed U.S. documents. The company’s tax ID information is a separate requirement.
Do not email passports or other identity records in response to an unexpected demand. First confirm who is asking, why the information is needed, and how it will be handled. Use a verified contact route rather than the reply link in a suspicious message.
Check an old reminder
Keep the message while you check it. Note the sender, date, named entity, claimed deadline, and requested payment or documents. A reminder may have been created under a rule that no longer applies.
Next, compare the entity name with its formation record. Where was it created? Did it later register in the U.S.? Keep those facts with the current official guidance you used to check the duty.
Finally, ask whether the message concerns FinCEN BOI reporting or a different task. A bank’s request, a Florida annual report, and a tax return are different tasks. If the notice is unclear, ask the sender which rule requires action. Check it before paying for help or sending private records.
If you or a provider saved the earlier deadline article, mark that copy as outdated. Replace its filing assumptions with a dated review of the current rule and your entity’s formation facts.
Other business duties still apply
The BOI exemption does not erase tax, licensing, contract, or state filing duties. For example, Florida’s annual report is a separate state record update. Do not use old BOI text elsewhere on a website to override FinCEN’s current rule.
A change in ownership, location, staff, or services may call for its own review. Our article on legal checks as a business grows addresses those broader questions. For a focused discussion of reporting status, see the firm’s current BOI guidance.
Bring the notice and formation records
Discuss the entity and the request with Katz & Associates. Start with whether a duty exists, not an assumption that a filing package is needed.
Common questions
It is not a current BOI filing deadline for a U.S.-created company under the final rule described here. Check whether a notice is instead about another obligation.
Not by itself. The key distinction is creation under a foreign country’s law, not creation in a different U.S. state.
No. Determine whether the entity has a reporting duty first. A general warning or old checklist does not establish that it does.
About the author
By Katz & Associates. Published by Katz & Associates Law Firm.
This is general information. It does not decide whether your entity must report.
Sources checked October 26, 2026. The correction notice is retained to help readers who reached this page through its earlier deadline title.
