FinCEN Confirms Final CTA Reporting Requirements

On Tuesday, August 11, 2026, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) issued the long-awaited final rule permanently removing the requirement of millions of U.S. companies and U.S. persons to report beneficial ownership information to FinCEN under the CTA. However, the interim final rule—previously issued by FinCEN on March 21, 2025 that narrowed the scope of the CTA to foreign companies only—continues to apply in the final rule.

For U.S. Persons, the agency announced its plans to delete previously reported information from the beneficial ownership information (BOI) database. Although unclear as to how such information will be deleted, the agency stated that it is “implementing a process to delete information about any individuals—company applicants, beneficial owners, or recipients of a FinCEN ID—that FinCEN reasonably believes was provided by a U.S. person (e.g., U.S. passport, U.S. driver’s license).” In doing so, the agency “anticipates working with the National Archives and Records Administration (NARA) to ensure FinCEN is abiding by all applicable Federal records laws.” We will provide updates on this BOI deletion process as FinCEN releases more information.

The U.S. Department of the Treasury issued a press release summarizing the scope of the final rule, which mirrors and makes permanent the interim final rule we published in March 2025.

In sum, the final rule:

• Makes permanent the March 2025 interim final rule exempting most U.S. companies from beneficial ownership reporting.
• Eliminates the requirement for U.S. persons with FinCEN IDs to update or correct their information.
• Removes the requirement for foreign companies to report U.S. company applicants.
• Exempts U.S.-registered foreign pooled investment vehicles from reporting U.S. persons who control them.
• Confirms that FinCEN will delete beneficial ownership and FinCEN ID information for individuals it reasonably determines are U.S. persons.

Under the final rule, foreign entities that are reporting companies will still be required to report beneficial ownership information for foreign individuals.

Please see below for our previous updates on the CTA:

• GAO Highlights Critical Gaps in CTA Interim Final Rule
• Corporate Transparency Act Obligations for U.S. Companies Are No More
• CTA: Clear Deadline, Unclear Future
• SCOTUS Hands Down CTA Decision — FinCEN Says Reporting Requirements Remain on Pause
• CTA Reporting Paused—Again!
• Corporate Transparency Act Injunction Lifted, Deadline to File Extended
• CTA Update: U.S. Government Appeals Injunction & FinCEN Issues Guidance
• Upset in the 11th Hour: Corporate Transparency Act Halted, for Now
• FinCEN Engages in Outreach as CTA Deadline Looms
• FinCEN Issues Update to Corporate Transparency Act
• The Corporate Transparency Act: Will it Impact You?