Beneficial Ownership Information (BOI) Reporting in 2026: What CPAs and Their Clients Need to Know

Part of our 2025 Tax Law Changes guide — the complete breakdown of the One Big Beautiful Bill Act.

Few compliance topics have caused more confusion for small businesses and their advisers than beneficial ownership information (BOI) reporting under the Corporate Transparency Act (CTA). The requirement has been enacted, enjoined, reinstated, and narrowed — so here is a plain-English summary of where BOI reporting stands and what it means for CPAs and their clients.

What the Corporate Transparency Act required

The CTA directed the Financial Crimes Enforcement Network (FinCEN) to collect BOI — the names, birthdates, addresses, and identifying numbers of the individuals who own or control a company — from millions of “reporting companies.” The stated goal was to combat money laundering and the use of anonymous shell companies.

The major change advisers need to know

In an interim final rule issued in early 2025, FinCEN significantly narrowed the rule’s scope. Under that guidance, entities created in the United States (and U.S. persons who are beneficial owners) were exempted from the BOI reporting requirement. The obligation was limited to “foreign reporting companies” — entities formed under the law of a foreign country that register to do business in a U.S. state — and even those companies are not required to report the information of U.S.-person beneficial owners.

What this means for your clients

• Most U.S. small businesses: under the current interim rule, domestic entities are not required to file a BOI report.
• Foreign-formed entities registered in a U.S. state: a filing obligation may still apply, with its own deadlines.
• Everyone: because this area has changed repeatedly, verify the current status directly on FinCEN’s BOI page before relying on it.

A note on scope of practice

Advising a client on whether and how to make a legal filing can edge into the practice of law. When in doubt, coordinate with the client’s attorney and stay within the bounds of your engagement and your state’s rules. A current professional ethics course is a good way to keep those boundaries fresh.

Stay current with CPE Options

Keeping up with fast-moving tax and accounting changes is exactly what continuing education is for. Browse our course catalog, lock in a full year with an Unlimited Access plan, or see all CPE plans. Not sure what your license requires? Check your state’s CPE requirements.

This article is general information for tax and accounting professionals and is not legal, tax, or accounting advice. Rules in this area change frequently and have been subject to litigation and agency updates — always confirm the current guidance from the relevant authority (IRS, FinCEN, AICPA, or your state board) before acting or advising clients.