BOI / CTA Status Tracker: All Updates Since January 2024
By Zawwad Ul Sami, Founder · Updated August 2, 2026
Published May 15, 2026 | Last updated August 2, 2026
Current BOI status (as of August 2026)
BOI reporting is not requiredfor domestic reporting companies, which includes every Wyoming LLC. FinCEN's March 21, 2025 interim final rule (90 FR 13688) exempts them. Foreign reporting companies registered to do business in a US state must still file within 30 days of registration.
This tracker is reviewed weekly and within 48 hours of any material FinCEN action, court ruling, or Federal Register publication.
Last verified: August 2, 2026
This page tracks every significant regulatory and legal development affecting Beneficial Ownership Information reporting under the Corporate Transparency Act. Timeline entries are ordered newest first.
Quick Answer
As of August 2026, domestic reporting companies including all Wyoming LLCs are exempt from BOI filing under FinCEN's March 21, 2025 interim final rule. Only foreign reporting companies must file.
What Is the Current BOI Status for Domestic Companies?
Under the FinCEN interim final rule published March 21, 2025 (90 FR 13688), all domestic reporting companies are exempt from BOI filing requirements. This includes every Wyoming LLC, regardless of ownership structure or member nationality. Only foreign reporting companies, entities formed under foreign law and registered to do business in the United States, remain obligated to file. FinCEN has indicated it will conduct further rulemaking to assess whether to reimpose domestic filing obligations. Until a revised final rule is published, no domestic entity has a BOI filing obligation, no domestic entity faces penalties for non-filing, and no previously filed reports by domestic entities require updating. This is the operative status as of the last update date shown above.
90 FR 13688 (Mar. 21, 2025)
Update Log
Every editorial review of this tracker is logged below, newest first, whether or not the underlying status changed.
- August 2, 2026: Reviewed. No change. Domestic reporting companies remain exempt under the March 21, 2025 interim final rule (90 FR 13688). No revised FinCEN rule has been published in the Federal Register.
- May 15, 2026: Reviewed. No change. Domestic exemption in effect; foreign reporting companies still obligated to file within 30 days of US registration.
- March 21, 2025: Status changed. FinCEN published the interim final rule exempting all domestic reporting companies, ending the filing obligation for Wyoming LLCs.
What Is the Complete BOI Timeline (Newest First)?
March 21, 2025: FinCEN Publishes Interim Final Rule Exempting Domestic Companies
FinCEN published an interim final rule at 90 FR 13688 narrowing the definition of "reporting company" under the CTA to include only foreign reporting companies. All domestic entities , corporations, LLCs, LPs, and other entities formed by filing with a US secretary of state, are exempt from BOI filing requirements effective immediately. The IFR stated that FinCEN intends to conduct a separate rulemaking process to assess whether and how to apply BOI requirements to domestic entities in the future. This rule resolved the practical compliance uncertainty created by the preceding months of court rulings and enforcement changes. Wyoming LLCs, as domestic entities formed under Wyoming state law, are fully exempt under this rule.
90 FR 13688
January 23, 2025: Supreme Court Reinstates BOI Enforcement
The Supreme Court of the United States granted the government's application to stay the district court injunction in Texas Top Cop Shop Inc. v. McHenry (formerly Garland), effectively reinstating FinCEN's authority to enforce BOI reporting requirements nationwide. This reversed the practical effect of the nationwide injunction that had been in place since early December 2024. Following the Supreme Court action, FinCEN announced extended deadlines for BOI reporting to account for the period during which enforcement was paused. However, the subsequent March 2025 IFR mooted the deadline extension for domestic entities by exempting them entirely.
December 23, 2024: Fifth Circuit Vacates Nationwide Injunction
A motions panel of the US Court of Appeals for the Fifth Circuit granted the government's motion to stay the nationwide injunction issued in Texas Top Cop Shop Inc. v. Garland. This temporarily restored FinCEN's enforcement authority and BOI filing deadlines. However, the situation remained fluid as additional legal challenges continued in other courts. FinCEN issued guidance indicating that reporting companies should file by updated deadlines that accounted for the injunction period. The rapid sequence of injunction, stay, and reinstatement created significant compliance confusion for small business owners nationwide.
December 3, 2024: NFIB v. Yellen Nationwide Injunction
The US District Court for the Eastern District of Texas issued a nationwide preliminary injunction in National Small Business United v. Yellen (originally Smith v. U.S. Department of the Treasury) halting enforcement of the CTA's BOI reporting requirements. The court held that the plaintiffs were likely to succeed on their claim that the CTA exceeded Congress's enumerated constitutional powers. The nationwide scope of the injunction temporarily relieved all reporting companies of filing obligations. FinCEN issued a statement acknowledging the injunction and indicating it was not enforcing BOI filing deadlines while the injunction remained in effect. This was the first nationwide pause in BOI enforcement since the CTA took effect on January 1, 2024.
January 1, 2024: CTA Implementing Rule Takes Effect
FinCEN's final rule implementing the CTA's BOI reporting requirements took effect on January 1, 2024. Under the implementing rule at 31 CFR 1010.380, reporting companies formed before January 1, 2024 had until January 1, 2025 to file initial BOI reports. Companies formed on or after January 1, 2024 were required to file within 90 days of formation (later reduced to 30 days for entities formed after January 1, 2025). The rule defined reporting companies, beneficial owners, company applicants, and the 23 categorical exemptions. The BOI E-Filing system at boiefiling.fincen.gov went live simultaneously, accepting electronic filings. This date marked the beginning of active BOI enforcement under the CTA.
31 CFR 1010.380
January 1, 2021: Corporate Transparency Act Enacted
The Corporate Transparency Act was enacted as part of the National Defense Authorization Act for Fiscal Year 2021 (Public Law 116-283). The CTA directed FinCEN to establish a beneficial ownership information reporting regime for certain entities formed or registered to do business in the United States. The statute established the basic framework: reporting companies must disclose beneficial owners and company applicants to FinCEN, with civil and criminal penalties for willful violations. The CTA gave FinCEN authority to promulgate implementing regulations, which were finalized in September 2022 with an effective date of January 1, 2024. The three-year gap between enactment and the implementing rule's effective date allowed FinCEN to build the BOI reporting infrastructure and E-Filing system.
Public Law 116-283, Section 6403; 31 USC 5336
What Does the Current BOI Status Mean for Wyoming LLC Owners?
For owners of Wyoming LLCs and other domestic entities, the practical impact of the current regulatory status is straightforward: you have no BOI filing obligation. You do not need to file an initial report, you do not need to update any previously filed report, and you face no penalties for non-filing. This applies whether you formed your Wyoming LLC in 2020 or in 2026, whether you are a single-member LLC or a multi-member LLC, and whether you are a US citizen, a permanent resident, or a non-US person. The domestic exemption is based solely on the entity's jurisdiction of formation, not on the nationality or residency of its owners. A Wyoming LLC owned entirely by citizens of another country is still a domestic entity because it was formed under Wyoming law. That said, this status is the result of an interim final rule, not a permanent statutory change. The CTA itself still authorizes BOI reporting for domestic entities. FinCEN has stated its intent to revisit domestic filing requirements through future rulemaking. Prudent LLC owners should maintain awareness of FinCEN developments and be prepared to comply if obligations are reimposed.
What Can Change in Future BOI Rulemaking?
Several scenarios can alter the current domestic exemption. FinCEN can issue a revised final rule reimposing BOI filing requirements on all domestic reporting companies, with new deadlines for initial filings. This would restore the original CTA framework as implemented before the March 2025 IFR. FinCEN can issue a modified rule imposing filing requirements on only certain categories of domestic entities, such as entities formed after a specific date or entities in certain industries. Congress can amend or repeal the CTA, permanently eliminating or modifying BOI requirements. Courts can issue rulings on pending constitutional challenges that affect FinCEN's authority to collect BOI from domestic entities. Any future rule reimposing domestic filing obligations would go through the federal rulemaking process, including a notice-and-comment period under the Administrative Procedure Act. This process takes several months to complete, providing advance notice before new obligations take effect. WLF monitors the Federal Register, FinCEN announcements, and relevant court dockets and will update this tracker and notify clients of any changes that affect filing obligations.
Related BOI Resources
Who Must Report
Reporting company definitions and entity types.
23 BOI Exemptions
All categorical exemptions explained.
BOI Penalties
Civil and criminal consequences.
How to File BOI
Step-by-step filing guide.
Foreign Reporting Companies
Requirements for entities formed abroad.
FinCEN Identifier
What it is and how to get one.
BOI Status Tracker: Frequently Asked Questions
Stay informed on BOI requirements
WLF monitors all FinCEN rulemaking and will notify clients of changes. Managed BOI filing: $150. Wyoming LLC formation: $497.
See also: BOI Reporting Guide | BOI Compliance Service | Pricing
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