FinCEN BOI Reporting for Non-Resident LLC Owners
Good news for most founders: a US LLC, even one owned entirely by a non-resident, no longer files a Beneficial Ownership Information report. Here is exactly who still does.
Quick Answer
No, a US-formed LLC does not need to file a BOI report in 2026, regardless of where its owners live. FinCEN's final rule, effective August 14, 2026, permanently removed the requirement for US companies and US persons. Only entities formed under foreign law that register to do business in a US state still report.
What Changed
Interim final rule
FinCEN announced it was removing the requirement for US companies and US persons to report beneficial ownership information.
Final rule issued
FinCEN made the exemption permanent, confirming that all entities created in the United States are exempt from BOI reporting.
Final rule takes effect
Reporting company status now applies only to entities formed under foreign law that register to do business in a US state or tribal jurisdiction.
Who Still Has to Report?
Reporting now depends on where the company was formed, not who owns it.
| Entity | BOI report required? | Why |
|---|---|---|
| Wyoming, Delaware or New Mexico LLC owned by a non-resident | No | US-formed, exempt |
| Any other US-formed LLC or corporation | No | US-formed, exempt |
| UK Ltd that does not register to do business in the US | No | Not registered in a US state |
| Foreign-formed company registered to do business in a US state | Yes | Still a reporting company |
| UK Ltd that registers in a US state to operate there | Yes | Still a reporting company |
Banks and Stripe still ask who owns your company
FinCEN no longer collecting ownership data from US LLCs does not change what Mercury, Wise, Stripe or any other platform requires. Their Know Your Business reviews still ask for the beneficial owners behind the company and for documents that prove it.
- A signed Operating Agreement showing ownership
- A Member Registry or cap table
- Passport for every 25%+ owner
- Matching legal name across every document
Frequently Asked Questions
Do non-resident LLC owners have to file a BOI report in 2026?
No. FinCEN's final rule, effective August 14, 2026, permanently removed beneficial ownership reporting for companies created in the United States and for US persons. That includes a Wyoming, Delaware or New Mexico LLC owned entirely by a non-resident.
Who still has to file a BOI report?
Only entities formed under the law of a foreign country that have registered to do business in a US state or tribal jurisdiction. A US-formed LLC is not required to report, and neither is a UK Ltd that has not registered to do business in the US.
What happened to the BOI deadlines and the $591 per day penalty?
FinCEN has said it will not enforce reporting deadlines, penalties or fines against US companies or US persons. The civil penalty of up to $591 per day for willful violations remains the figure for entities that are still required to report and do not.
Why did the rules change so many times?
The Corporate Transparency Act reporting rules were challenged in court and revised repeatedly. FinCEN issued an interim final rule on March 21, 2025 exempting US companies, then made that permanent with a final rule on August 11, 2026, effective August 14, 2026.
Do banks and Stripe still ask who owns my LLC?
Yes. They run their own Know Your Business checks and ask for beneficial owner details plus documents like your Operating Agreement and Member Registry. FinCEN no longer collecting the data does not remove that requirement from your bank.
Is BOI information public?
No. Information held in FinCEN's database is not public. It is accessible only to authorized government agencies and certain financial institutions for compliance purposes.
Does HynoGo still file BOI reports?
Yes. HynoGo prepares and submits BOI reports for a flat $35. We check your entity against FinCEN's current rules first, for free, so you know whether your entity must report (for example a foreign-formed company registered to do business in a US state) before you pay.
Sources: FinCEN: Beneficial Ownership Information Reporting and US Treasury announcement of the final rule. This page is general information, not legal advice.
Not Sure If You Need to File?
Tell us where your company was formed and whether it is registered in a US state. We confirm your BOI status for free, then prepare and submit your BOI report for a flat $35.
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