The Corporate Transparency Act (CTA) went into effect on January 1, 2024, originally requiring both domestic and foreign reporting companies to submit beneficial owner information (BOI) to the Financial Crimes Enforcement Network (FinCEN).

As of 2026, following FinCEN's interim final rule published on March 26, 2025, the definition of "reporting company" now includes only foreign entities that have registered to do business in a U.S. state or Tribal jurisdiction. Entities formed in the United States, previously known as domestic reporting companies, are no longer required to submit BOI reports, update information, or correct previously filed details.

This guide explains which businesses are still required to file, the deadlines that applied to those foreign reporting companies, and considerations for submitting accurate information.

We'll also introduce Harbor Compliance and highlight how our BOI Reporting Service can help foreign entities manage reporting efficiently and with less effort.

CTA Violations and Penalties

According to the U.S. Code (31 U.S.C. 5336(h)(2)), there are two distinct BOI reporting violations:

1. Willful provision or attempt to provide false or fraudulent BOI, documents, or photos
2. Willful failure to provide a complete, updated BOI report

Both violations can result in civil or criminal penalties, which are outlined in the following table:

Type	Penalty
Civil	$591 per day of continued violation + inflation*
Criminal	A fine of no more than $10,000, up to two years of imprisonment, or both

^*Penalties are adjusted annually based on inflation.

The U.S. Code also prohibits any unauthorized use or disclosure of BOI. The civil penalty for this violation is the same, while the criminal is higher—up to five years of imprisonment and a fine of up to $250,000 (or both).

How To Prevent CTA Violations

If you want to avoid the aforementioned penalties, you must take two steps:

1. Submit your initial BOI report within the prescribed timeframe
2. Correct any mistakes and update your BOI regularly

When Do You Need To Submit the Initial BOI Report?

The timeframe for submitting a BOI report applies only to entities that meet FinCEN's current definition of a "reporting company," which now includes only foreign entities registered to do business in a U.S. state or Tribal jurisdiction. Domestic entities—those formed in the United States—are exempt from BOI reporting, including initial submissions and updates.

For foreign reporting companies, the original deadlines were as follows:

• Entities registered to do business in the United States before March 26, 2025, were required to file BOI reports by April 25, 2025.
• Entities registering on or after March 26, 2025, had 30 calendar days to submit an initial BOI report after receiving notice that their registration was effective.

These deadlines applied only to foreign entities that did not qualify for an exemption and were subject to the interim final rule announced by FinCEN in March 2025.

The CTA also differentiates between actual and public notices, and the following table explains both types:

Notice Type	Explanation
Actual	Official correspondence from the secretary of state or similar authority received by the company
Public	Provided through a public registry managed by the secretary of state or equivalent regulatory body

Depending on your jurisdiction, you might have received either or both types of notices in the past. If both were issued, the 30-day period originally started from the date of the earlier notice.

As of the FinCEN interim final rule issued in March 2025, only foreign entities that meet the current definition of a reporting company are required to submit BOI reports. U.S.-formed entities and their beneficial owners are no longer required to file. Foreign entities that registered on or after March 26, 2025, and do not qualify for an exemption, would have submitted their initial BOI report within 30 calendar days of receiving notice that their registration was effective.

Keep Your BOI Accurate and Updated

Submitting the initial BOI report is only one part of the process—and one that was simpler compared to ongoing updates. Under the current FinCEN rules, only foreign entities that meet the definition of a reporting company are required to keep their BOI information current. Domestic entities—those formed in the United States—are no longer required to submit updates or correct previously filed information.

Foreign reporting companies should continue to ensure FinCEN has accurate information about their beneficial owners. For example, if a beneficial owner's government-issued photo ID changes, the previously submitted document is no longer considered valid.

While deadlines for reporting updates were originally set, the interim final rule issued by FinCEN in March 2025 now exempts domestic entities from ongoing reporting obligations and clarifies that only foreign reporting companies must follow update requirements.

This structure helps reduce uncertainty around BOI reporting. For foreign entities that do need to maintain accurate records, Harbor Compliance can assist in managing updates efficiently and minimizing the risk of mistakes.

Avoid Potential Penalties by Filing BOI Reports on Time for Foreign Entities

FinCEN has clarified that the requirement to report BOI applies only to foreign reporting companies under the revised definition of "reporting company." U.S. entities, including those previously considered domestic reporting companies, and their beneficial owners are no longer required to submit BOI reports or updates.

Foreign entities that meet the current reporting company definition and are not exempt must still report their BOI to FinCEN. These entities are not required to report any U.S. persons as beneficial owners, and U.S. persons are not required to provide BOI for such entities.

Deadlines for foreign reporting companies were established in the interim final rule:

• Reporting companies registered to do business in the United States before March 26, 2025, had a filing deadline of April 25, 2025.
• Reporting companies registered on or after March 26, 2025, were required to submit their initial BOI report within 30 calendar days of receiving notice that their registration was effective.

With the initial reporting period concluded, the focus for foreign reporting companies is now on maintaining accurate records under the current requirements. Working with a trusted BOI reporting service like Harbor Compliance can help foreign entities manage updates efficiently and reduce the risk of errors.

Avoid Hefty CTA Penalties

Starting the process early can help ensure foreign reporting companies have accurate and complete information on hand, making it easier to manage updates or corrections if needed. You can simplify this process by working with a trusted BOI Reporting Service provider like Harbor Compliance.

Order Harbor Compliance's BOI Reporting Service Now

Enjoy Risk-Free BOI Reporting With Harbor Compliance

To help you enjoy peace of mind and focus on core business operations without worrying about CTA regulations, we offer a convenient and reliable BOI Reporting Service. It gives you a mostly hands-off approach to reporting since we take care of the entire filing process to free up your time.

When you partner with us, we'll gather your BOI and submit it to FinCEN. More importantly, we'll provide ongoing support to help you keep the report accurate and updated.

Our service is available to all reporting companies, most notably:

• Corporations and LLCs
• Nonprofits that aren't 501(c) exempt
• Small businesses
• Multientity businesses
• Multinational companies

Benefits of Entrusting BOI Reporting to Harbor Compliance

The main reason you should engage with us is extensive know-how and expertise. Harbor Compliance is one of the nation's leading providers of compliance solutions, and we can help your organization run without regulatory setbacks, regardless of its ownership and leadership structure.

After filing your initial BOI report, we'll send you regular reminders to check whether any information needs to be updated. This means you don't need to wonder if anything has slipped through the cracks and might be considered a violation of the CTA.

You can also keep track of your company's ownership information through the optional Records Manager add-on. With all data laid out clearly in a centralized system, you won't have to scour lots of documents or spreadsheets to find BOI.

Harbor Compliance also takes care of any report corrections that might be necessary. If you notice that any of the provided information is inaccurate, we'll help you resolve this issue within the required timeframe and avoid penalties. You can use our BOI Reporting Service for up to four initial, corrected, and/or updated reports per year.

How To Order Our BOI Reporting Service

You can get started with our BOI Reporting Service in a few quick steps:

1. Go to the signup wizard
2. Choose from three options suitable for different reporting needs:
   1. Single business
   2. Nonprofit that is not 501(c) exempt
   3. Multiple entities
3. Fill out the form by entering your contact and company details
4. Check out

When you order the service, we'll collect your BOI and submit the initial report to FinCEN on your behalf. If there's a change in your beneficial ownership structure or any relevant information, notify us, and we'll report it to FinCEN accurately and timely.

Explore Our Additional Solutions

Effective BOI reporting is only one aspect of ensuring your organization runs in accordance with state and federal laws. You must check numerous other boxes, which can be overwhelming and prevent you from focusing your attention on impactful work.

If you need help meeting your obligations, you can explore our rich service portfolio. We offer solutions for virtually all the key regulatory requirements, so we can contribute to your organization's uninterrupted operations.

Whenever you need to file something with the secretary of state or a similar authority, you can use our Drop-Off Filing Service. It lets us hand out your documents in person, which gives them priority and expedites the filing process. We can also obtain important documents in your name, including:

• Certificate of good standing
• Certificate of authority
• Articles of reinstatement
• Certified copies

Harbor Compliance provides comprehensive support throughout your organization's lifecycle. You can take advantage of various services, such as:

• Business name reservation
• DBA management
• Initial report
• Annual reports
• Amendments

We can also serve as your organization's registered agent to efficiently receive and forward your legal or government notices. You can use our services even if you already have an agent because we can help you switch to another one.

Other notable services include the following:

• General business licenses and industry-specific ones (construction, engineering, etc.)
• Tax-related services (e.g., obtaining an EIN, payroll tax registration, and sales and use tax registration)
• Nonprofit incorporation or charitable registration alongside a 501(c) tax exemption

BOI Reporting FAQs

Below, you'll see some of the most commonly asked questions about BOI reporting. If you need additional guidance, you can explore our robust Information Center alongside FinCEN's FAQ page.

Prevent CTA Penalties With Harbor Compliance

If you want to minimize the risk of exposing yourself to CTA violations and penalties, order our BOI reporting service today. We'll help you file the initial report and all the necessary updates or corrections timely and effortlessly.

To get a clear overview of how well your organization meets other regulatory requirements, get a free Harbor Compliance Score™. If there are any pending obligations you should meet promptly, reach out to us to inquire about the other services we offer.

You can also take advantage of our award-winning compliance platform that makes it easy to keep your organization aligned with important regulations. Schedule a demonstration to see it in action.