BOI reporting in 2026: does your US LLC still have to file?

No. An LLC formed by a filing with a US state, whether Wyoming, Delaware, New Mexico or any other, does not file a beneficial ownership information (BOI) report with FinCEN, the US Treasury's Financial Crimes Enforcement Network. That is true whoever owns it and wherever the owner lives. FinCEN's final rule, published and effective on 14 August 2026, made permanent an exemption that has applied since March 2025: the only "reporting companies" left are entities formed under the law of a foreign country and registered to do business in a US state (Federal Register; FinCEN, checked 29 October 2026).

That answer covers FinCEN only. Your LLC's state filings, its IRS information return and your bank's identity checks are separate obligations, decided by separate authorities, and none of them changed. This guide explains who still reports, the one FinCEN duty that can still apply to a non-US founder, how to check a BOI letter or paid add-on, and what your LLC still owes each year.

In brief (checked 29 October 2026)

• An LLC formed in a US state is a domestic company. Under FinCEN's final rule (91 FR 52508) it is not a reporting company, so it files no initial BOI report and no updates.
• The owner's nationality and residence do not matter. A Wyoming LLC owned by someone living in Egypt is exempt on the same terms as one owned by a US citizen.
• Companies formed under foreign law, for example in Egypt or the UAE, that register to do business in a US state still report unless an exemption applies. If registered on or after 26 March 2025, they have 30 calendar days from notice that the registration is effective.
• If you are not a US person and you obtained a FinCEN ID, you must still update or correct it within 30 calendar days of a change, or of learning the information was wrong.
• FinCEN charges no fee to file BOI and does not send payment requests. Letters about a "Form 4022", a "Form 5102" or a "US Business Regulations Dept." are fraudulent.
• Your state annual report or tax, Form 5472 with a pro forma Form 1120, your registered agent and your bank's own checks are unchanged.

What changed, in five dates

Date	What happened
1 January 2024	FinCEN's BOI reporting rule under the Corporate Transparency Act took effect; US-formed companies were expected to report
Late 2024 to early 2025	Court orders paused the rule; FinCEN extended most deadlines to 21 March 2025
2 March 2025	Treasury suspended enforcement against US citizens and domestic reporting companies
26 March 2025	An interim final rule (90 FR 13688) took US-formed companies out of the definition of "reporting company"
14 August 2026	The final rule (91 FR 52508) adopted the interim rule with limited changes, published and effective the same day

FinCEN announced the final rule on 11 August 2026. A guide written in 2024 that tells every LLC to file by a deadline describes rules that no longer apply. FinCEN's own BOI page now tells readers to disregard any guidance on its site saying US companies or their beneficial owners must report (FinCEN).

Why a US LLC with a non-US owner is exempt

The test is where the company was formed, not who owns it.

FinCEN's original rule had two kinds of reporting company. A domestic reporting company was one created by filing a document with a secretary of state under the law of a US state. A foreign reporting company was one formed under the law of a foreign country and registered to do business in a US state. The 2025 interim rule removed the first group from the definition, and the final rule keeps it that way: "reporting company" now means only entities formed under foreign law and registered in a US state, the ones formerly called foreign reporting companies (Federal Register).

Your LLC came into existence when its formation document was filed with the state, which in Wyoming means its Articles of Organization (US LLC documents explained covers what each document is). That makes it a domestic entity for FinCEN, whether its owner lives in Cairo, Riyadh or Texas. The test does not depend on the owner's passport, residence or tax status.

Watch the word "foreign". In state filings, "foreign LLC" usually means an LLC formed in one US state and registered to do business in another. A Wyoming LLC registered in a second state is "foreign" in that state's records, but it is still formed under US state law, so it is not a FinCEN reporting company. For FinCEN, "foreign" means formed under the law of another country. The federal rule does not change state disclosure laws, though: if your company registers in another state, check that state's current requirements.

Who still files a BOI report

An entity is a reporting company today if it was formed under the law of a foreign country, registered to do business in a US state or tribal jurisdiction by a filing with a secretary of state or similar office, and does not qualify for one of the rule's exemptions (FinCEN).

For founders in Egypt and the Gulf, the realistic case is an existing company formed at home, in Egypt, Saudi Arabia or the UAE for example, that registers in a US state to operate there. Forming a new US LLC is a different case, covered above.

• Initial report. A reporting company registered on or after 26 March 2025 has 30 calendar days after it receives notice that its registration is effective to file its first report.
• US persons are left out. It does not report US-person beneficial owners or US-person company applicants, and US persons do not have to give it their information.
• Updates. A reporting company files an updated report within 30 days of a change to information it reported earlier (Federal Register).

Filing directly with FinCEN through its BOI E-Filing System costs nothing. If this is your situation, read FinCEN's current guidance and exemptions before the 30 days run out.

Your situation at a glance

Your situation	Files a BOI report?	What still applies
LLC formed in a US state, owner outside the US	No	State, IRS and bank requirements
LLC formed in a US state, US owner	No	State, IRS and bank requirements
US LLC owned by your company in Egypt or the UAE	Not for the LLC	The parent reports only if it registers in a US state
Company formed in Egypt, the UAE or elsewhere, registered in a US state	Yes, unless exempt	First report within 30 days of notice; no US-person owners
You hold a FinCEN ID and are not a US person	Not on that basis alone	Update it within 30 days of a change, or correct it within 30 days of learning it was wrong

The FinCEN ID: the duty that can still reach a non-US founder

A FinCEN ID is an optional identifying number that FinCEN issues to an individual on request, after the person submits certain information. Some people obtained one before the 2025 changes, to streamline reporting for the companies they owned or helped form.

The final rule removed the duty to keep a FinCEN ID up to date, but only for US persons. If you obtained a FinCEN ID and you are not a US person, an Egyptian citizen living in Egypt for example, the revised rule (31 CFR 1010.380(b)(4)(iii)(A)) still requires you to:

• file an updated application within 30 calendar days after any change to the information you submitted; and
• file a corrected application within 30 calendar days after you learn, or have reason to know, that the information was wrong.

FinCEN explains the difference in the final rule: a non-US holder is either connected to a company that still reports, or obtained the ID because their information was expected to be reported, so it is more likely to be needed again (Federal Register).

In practice, if you never applied for a FinCEN ID, there is nothing to do. If you did, or if you are not sure whether whoever handled your 2024 filing obtained one in your name, find out, and keep its information current.

If you already filed a BOI report in 2024 or early 2025

For a US-formed LLC there is nothing to update, correct or withdraw. Domestic companies have no reporting obligation, initial or ongoing, so you do not need to tell FinCEN about a new address or a change of members.

The final rule also discusses the information already filed. FinCEN says it intends a one-time process to remove the BOI of US companies and US persons that are now exempt, deleting information about individuals who reported an identifying document it reasonably believes was provided by a US person, such as a US passport or driver's license. It does not anticipate asking US companies or US persons to contact it to request removal, it does not intend to send confirmations, and it will post a notice on its website when the process is complete. It also says it does not anticipate deleting US-company or US-person information included in a filing made after 10 February 2027 (Federal Register). The rule ties the deletion of individuals' information to US identity documents; it does not specifically say what happens to information a non-US owner reported for a US company, such as an Egyptian passport, so do not assume it has been deleted.

Since FinCEN does not plan to ask US companies or US persons to request removal, an offer to "remove" or "withdraw" an old report for a fee deserves the same questions as any other BOI offer.

BOI scams and paid add-ons

FinCEN's BOI page lists the warning signs it has seen (FinCEN, checked 29 October 2026):

• There is no fee to file BOI directly with FinCEN, and FinCEN does not send correspondence asking for payment to file.
• FinCEN has no "Form 4022" or "Form 5102". Correspondence that refers to them is fraudulent.
• There is no "US Business Regulations Dept." No government entity has that name.
• FinCEN does not send initial correspondence about penalties by email or phone.
• Be cautious of any letter or email that asks you to click a suspicious link or scan a QR code.

How to check a BOI letter or offer

Ask three questions, and get the answers in writing:

1. What filing is this, by name? A real filing has a name you can look up, such as "Form 5472" or "Wyoming annual report".
2. Which authority receives it? FinCEN, the IRS or a state secretary of state. Check on that authority's website by typing the address yourself, not through a link in the message.
3. Which rule requires it for my company? For an LLC formed in a US state, FinCEN's current answer is that US companies are exempt.

You may still see a "BOI filing" or "BOI compliance" add-on in a formation package or an annual compliance plan. You do not need one for a US-formed LLC. If a provider includes it, ask what you would be paying for.

What did not change

The exemption removes one federal report. Everything else your LLC owes is set by other authorities, and it stays the same.

Obligation	Who decides	What it involves
Wyoming annual report and license tax	Wyoming Secretary of State	Due the first day of your formation anniversary month; at least $60 for an LLC
Delaware annual LLC tax	Delaware Division of Corporations	$400, due on or before 1 June for the prior year; no annual report
New Mexico state filings	New Mexico Secretary of State	No routine annual report in Foundlie's data; confirm with the state
Registered agent	Your formation state	Required for as long as the LLC exists
Form 5472 with pro forma Form 1120	IRS	Yearly, for a single-member LLC owned by a non-US person, when it has reportable transactions
Ownership and identity checks	Each bank or payment provider	Their own know-your-customer rules

State: annual report or tax

Wyoming. Every LLC files an annual report and pays a license tax to stay in good standing. The report is due each year on the first day of the month in which the company was formed, so an LLC formed on 15 May 2026 has its first report due on 1 May 2027. It can be filed up to 120 days early. The tax is $60 or $0.0002 per dollar of assets located and employed in Wyoming, whichever is greater; an LLC with $300,000 or less in such assets pays $60. If the report is not filed within 60 days after the due date, the state administratively dissolves the company. The Secretary of State sends courtesy reminders 60, 30 and 10 days before the due date from [email protected] (Wyoming Secretary of State, checked 29 October 2026).

Delaware. A Delaware LLC pays an annual tax of $400 and files no annual report. The tax for a year is due on or before 1 June of the next year, so the 2026 tax is due by 1 June 2027. Paying late adds a $200 penalty plus 1.5% interest a month on the tax and penalty (Delaware Division of Corporations, checked 29 October 2026).

New Mexico. Foundlie's cost data treats a New Mexico LLC as having no routine annual report or annual state fee. Confirm the current requirement for your LLC with the New Mexico Secretary of State before relying on it.

Wyoming vs Delaware vs New Mexico compares these obligations if you are still choosing a state.

Registered agent

Your LLC must keep a registered agent in its formation state. In Wyoming, losing one has a price: the fee schedule effective 1 July 2026 lists $350 to reinstate an LLC dissolved for having no registered agent (Wyoming Secretary of State). Registered agent vs virtual address vs business address explains what the agent's address is for, and what it cannot be used for. Foundlie's pricing page lists the formation price for each state together with the expected renewal costs.

IRS: Form 5472 with a pro forma Form 1120

By default, the IRS treats a US LLC with one owner as a disregarded entity: it is ignored for income tax, and its activity belongs to the owner. For the reporting rules of section 6038A, though, an LLC wholly owned by one foreign person is treated as a corporation. It files Form 5472 attached to a pro forma Form 1120 by the Form 1120 due date, 15 April for a calendar-year LLC, unless it had no reportable transactions that year. Those transactions include contributions to and distributions from the LLC and amounts paid or received in connection with its formation, so any year in which you put money into the LLC or took money out has one. The penalty for failing to file on time and in the prescribed manner is $25,000 (IRS). Form 7004 extends the time to file, not the time to pay any tax (IRS; Instructions for Form 7004).

FinCEN's rule changes none of this. The full process is in Form 5472 for a foreign-owned US LLC. Whether you personally owe US income tax is a separate question for a tax professional; Foundlie's US tax overview is a starting point.

Banks and payment providers

Banks and payment providers still ask who owns and controls your company. That is part of their own know-your-customer checks under the rules that apply to them, not a FinCEN filing, and the BOI exemption does not change it. Expect to provide ownership details, identity documents and your formation papers; what Mercury asks for is one example. Approval remains each provider's decision.

Frequently asked questions

Do I need to file BOI for my Wyoming LLC?

No. An LLC formed in Wyoming, or in any other US state, is a domestic company and not a reporting company under FinCEN's final rule, effective 14 August 2026. That applies whether you live in the United States or abroad. You still file the Wyoming annual report each year.

I got a letter asking me to pay for BOI filing. Is it real?

Treat it as suspicious. FinCEN charges no fee to file BOI, does not send payment requests, has no "Form 4022" or "Form 5102", and does not send initial penalty notices by email or phone. An LLC formed in a US state has no BOI report to file. Do not pay, click links or send personal information; check FinCEN's BOI page by typing the address yourself.

I filed a BOI report in 2024. Do I need to update it?

Not for a US-formed LLC. Domestic companies have no reporting or update obligation. The exception is personal: if you are not a US person and you obtained a FinCEN ID, update it within 30 calendar days of any change, and correct it within 30 days of learning of an error.

Does this change Form 5472?

No. Form 5472 is an IRS information return under the tax code, separate from FinCEN's BOI rule. A single-member LLC owned by a non-US person still files Form 5472 with a pro forma Form 1120 for each year it has reportable transactions, and the penalty for failing to file is $25,000.

My company in Egypt is registering to do business in a US state. Does it report?

Yes, unless it qualifies for an exemption. A company formed under foreign law and registered in a US state meets the current definition of a reporting company. If registered on or after 26 March 2025, it has 30 calendar days from notice that its registration is effective to file, and it does not report US-person beneficial owners.

What to do next

• If your LLC was formed in a US state: put your state deadline and your Form 5472 deadline in your calendar, and decline BOI offers.
• If you hold a FinCEN ID and are not a US person: keep a copy of what you submitted, and update it within 30 days of any change.
• If you are forming a company: US company formation covers the state filing, the registered agent and the EIN application, and the pricing page shows the first-year price and renewals by state. You can contact us if you are unsure which obligations apply to you.

This article provides general educational information and is not legal, tax or banking advice. FinCEN rules, state requirements, IRS procedures and provider policies change; check the current official source or consult a qualified professional for your situation.