BOI Reporting: What Still Applies After the 2025 Rule Change
Tousif Akram
IRS CAA · Founder, FormLLC
Disclaimer: This guide is for general informational purposes only. FormLLC is not a law firm or CPA firm. Consult a licensed professional for advice specific to your situation.
BOI reporting became one of the most confusing topics for founders because the rules changed after many earlier articles had already been published. If you own an LLC, you should not rely on 2024-era summaries without checking the current FinCEN position.
What BOI reporting was designed to do
BOI reporting under the Corporate Transparency Act was intended to require certain businesses to report information about beneficial owners and company applicants to FinCEN. The purpose was to improve transparency around company ownership and reduce misuse of anonymous entities.
The major rule change in 2025
In 2025, FinCEN issued an interim final rule that removed BOI reporting requirements for US-created entities, including domestic LLCs and corporations. That means many older blog posts saying “every US LLC must file BOI” are now outdated and can mislead founders.
Who may still need to pay attention
Certain foreign companies registered to do business in the United States may still have BOI obligations under the updated framework. So the right question is no longer “Does every LLC file BOI?” but rather “Is this entity domestic or foreign under the current FinCEN rule, and does the rule still apply to this entity type?”
Why older advice is risky
Many websites still repeat pre-2025 guidance, including automatic deadlines and civil penalty language written for the earlier reporting regime. Because the rule changed, founders should verify the latest official FinCEN page before acting. This is especially important for foreign founders reading recycled content from formation agencies, YouTube clips, or social posts.
How to handle BOI correctly now
The safest approach is to identify the exact legal status of the company, confirm whether it is domestic or foreign under the rule, and review the current FinCEN guidance directly before filing or deciding not to file. If the company has already filed, ownership records should still be maintained carefully for general compliance reasons even where a new BOI filing is no longer required.
Practical takeaway for foreign founders
If you formed a US LLC in the United States, do not assume that older BOI filing obligations still apply in the same way they did in 2024. If your entity is a foreign company registered in the US, review the current FinCEN guidance immediately and treat older “everyone must file” articles as outdated until verified.
This article is for general informational purposes only and does not constitute legal, tax, or financial advice. Tousif Akram and FormLLC are not a law firm or CPA firm. Consult a licensed professional for advice specific to your situation.
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