Every small LLC owner who filed a Beneficial Ownership Information (BOI) report in 2024–2025 is asking the same question in 2026: do I still file, amend, or do anything at all?
What FinCEN Changed
In 2026, FinCEN removed the BOI reporting requirement for domestic U.S. companies and U.S. persons. If your company is formed in a U.S. state, you are generally no longer required to file or update a FinCEN BOI report, even if you filed in 2024. Foreign companies registered to do business in the United States still file.
What stays: The BOI database still exists for foreign entities and for law enforcement access. Willful failure to file when required can still carry the $500 per day penalty and criminal exposure.
New York's Separate Law
New York did not follow FinCEN's pullback. The New York LLC Transparency Act now requires many LLCs formed or authorized in New York to file beneficial ownership information with the New York Department of State, with a $250 fee and a different deadline. A domestic U.S. LLC in New York may have no FinCEN duty but still have a New York duty.
Trigger: Formation or qualification in New York, with exemptions far narrower than the old FinCEN 23 exemptions — most small LLCs are in.
What to Do Now
- Confirm formation jurisdiction: U.S. domestic? FinCEN duty likely gone. Foreign? Still file FinCEN.
- Check New York status: If you have a New York LLC, prepare for the NY filing with the same BOI data: full legal name, birth date, address, and ID image of each beneficial owner.
- Keep records: Even without a filing, banks and counterparties will still ask for BOI at account opening. Keep the same beneficial ownership file you prepared for FinCEN.
Bookkeeping Tie-In
BOI is not accounting, but the filing requires the same cap table and ownership ledger that a lender and an insurer will ask for. A version-controlled beneficial ownership file that matches the ledger's equity accounts is the evidence that survives an account-opening review.
Beancount.io keeps equity ownership as transactions that tie to the BOI report — plain text, auditable, ready before the bank asks. Get started for free and make the transparency that outlives the federal form also ready for the state one.