Understanding Your Filing Requirements Under the Corporate Transparency Act

By Debbie Callen • 02/18/2026

If you own a business in the United States, you’ve likely heard conversations about the Corporate Transparency Act (CTA) and wondered whether it applies to you. With shifting guidance, federal updates, and legal decisions unfolding over the past few years, it hasn’t always been easy to know what’s required.

As of 2026, the rules are much clearer. Major revisions to the CTA and the Beneficial Ownership Information (BOI) reporting rules now mean that U.S.-based companies are no longer required to file. Below is a breakdown of what’s changed, what this means for your business, and how to stay prepared in case regulations evolve again.

What Is the Corporate Transparency Act?

The CTA became law in 2021 as part of the National Defense Authorization Act. Its core purpose was to curb illegal financial activity — such as tax evasion, money laundering, and the use of shell companies — by requiring certain businesses to disclose who ultimately owned or controlled them. These individuals are known as “beneficial owners.”

The required information was to be submitted to the Financial Crimes Enforcement Network (FinCEN), which is part of the U.S. Department of the Treasury. The intent was straightforward: make it harder for anonymous entities to engage in criminal financial behavior without oversight.

How the CTA’s Requirements Have Evolved

Originally, the CTA was set to take effect on January 1, 2024. It would have required a wide range of small and mid-sized U.S.-based businesses to submit BOI reports. But significant legal and administrative developments shifted the direction of the program.

The most important update came on March 26, 2025, when FinCEN released an interim final rule. This revision greatly narrowed the definition of a “reporting company.” Under the new interpretation, all entities formed in the United States — including LLCs, corporations, and partnerships — were removed from the reporting requirements. U.S. persons were also excluded from being named in filings submitted by foreign companies.

As a result, most businesses operating domestically no longer fall under CTA reporting obligations.

Who Must File Under the Current Rules?

With the revised definition in place, only foreign entities that are registered to conduct business in the U.S. are considered reporting companies.

If your company was formed in the United States — whether it’s an LLC, corporation, professional entity, or similar structure — you are no longer required to file a BOI report. The exemption applies regardless of foreign ownership or overseas operations, as long as the business itself is a U.S.-created entity.

Already Filed a BOI Report? Here’s What It Means

If your business submitted a BOI report before the March 2025 rule was issued, there’s nothing you need to do now. FinCEN has stated that companies that filed under earlier guidance are not required to update their submissions or take further action.

Those earlier filings are simply considered complete, and you are no longer subject to ongoing reporting requirements under current law.

How to Stay Ready for Possible Future Changes

Even though you’re not required to submit anything at the moment, staying informed is still important. Regulations can shift, and future court rulings or policy reviews could reinstate or modify the filing requirements.

Here are a few helpful steps to stay prepared:

Maintain your beneficial ownership details internally. Even though you don’t need to file right now, having this information organized will save time if rules change.
Monitor official updates from FinCEN or trusted advisors. FinCEN’s website provides the most reliable updates, and your legal or accounting professionals can help you understand how any regulatory shifts might affect your business.
Discuss international connections with compliance experts. Businesses with foreign investors or global operations may need more nuanced guidance, especially if definitions change again in the future.
Consider subscribing to compliance alerts. Industry organizations and legal or tax groups often provide early insights into regulatory developments.

Why the CTA Still Matters for U.S. Companies

Even though domestic businesses are currently exempt from CTA filing requirements, the law’s underlying purpose — increasing ownership transparency — is still a priority at the federal level. Policymakers may revisit reporting obligations if the current exemption is seen as creating unintended gaps in enforcement.

For this reason, adopting a proactive approach puts your business in a stronger position. Staying organized now helps ensure you can respond quickly if regulations shift again, without scrambling to gather information or navigate new rules under pressure.

We’re Here to Support Your Compliance Readiness

If you need help understanding CTA requirements or preparing your business for potential BOI reporting changes, our team is ready to assist. We’re here to help you navigate evolving regulations with confidence and keep your organization fully prepared.

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