As of 2026, most Texas LLCs do not have to file a Beneficial Ownership Information (BOI) report with FinCEN. A March 21, 2025 interim final rule exempted all US-formed domestic entities from the reporting requirement. Only foreign entities registered to do business in the United States must still file. This exemption may change — monitor FinCEN.gov for updates before assuming you are permanently off the hook.
What the BOI report was designed to do
The Corporate Transparency Act (CTA), enacted in 2021, required most US businesses to report their beneficial owners — the real people who own or control the company — to the Financial Crimes Enforcement Network (FinCEN), a bureau of the US Treasury. The goal was to reduce money laundering and other financial crimes enabled by anonymous shell companies.
Initially, all LLCs without a qualifying exemption were required to file. Texas LLCs formed before January 1, 2024 had until January 1, 2025. New entities had 90 days from formation.
What changed in March 2025
On March 21, 2025, FinCEN issued an interim final rule that fundamentally changed the scope of the CTA:
All US domestic entities — including Texas LLCs — are now exempt from BOI reporting.
Only entities formed under the laws of a foreign country and registered to do business in the United States are still required to file.
This exemption is the result of ongoing legal challenges to the CTA and a policy decision by the Treasury Department. As an interim final rule, it is in effect now — but it could be revised, replaced, or overturned by a court order or regulatory action.
Source: FinCEN.gov — BOI Reporting
What this means for your Texas LLC in 2026
If your LLC was formed in Texas (a domestic entity):
- You are currently exempt from BOI reporting
- You do not need to file an initial, updated, or corrected BOI report
- No penalty applies for not filing while the exemption is in place
If your LLC was formed outside the US and registered to do business in Texas (a foreign entity):
- You are still required to file a BOI report with FinCEN
- Visit fincen.gov/boi for current deadlines and filing instructions
If you already filed a BOI report before the exemption took effect:
- Your prior filing stands — there is no penalty or issue with having filed
- You are not required to withdraw or update it
How to monitor for changes
The BOI exemption is not permanently codified law — it is an interim final rule subject to change. If the CTA is reinstated for domestic entities, FinCEN would issue a new rule with a compliance deadline. Check fincen.gov/boi periodically, especially if you hear about new regulatory or court activity related to the Corporate Transparency Act.
In the meantime, your Texas state filing obligations remain unchanged. See the Texas LLC compliance checklist for everything your LLC owes at the state level each year.
Quick reference
| Detail | Info |
|---|---|
| What | Beneficial Ownership Information (BOI) report |
| Agency | FinCEN (Financial Crimes Enforcement Network) |
| Current status (2026) | Domestic US LLCs exempt as of March 21, 2025 interim final rule |
| Who still must file | Foreign entities registered to do business in the US |
| Where to file (if required) | fincen.gov/boi |
| Cost | Free to file (no filing fee) |
| Penalty if required and not filed | Civil penalties up to $591/day; criminal penalties for willful non-compliance |
FAQ
What happens if I don't file a BOI report as a Texas LLC?
Under the current exemption, nothing — domestic US LLCs are not required to file. If the exemption is ever reversed and a deadline is reinstated, failing to file within the new deadline could result in civil penalties up to $591 per day and potential criminal liability for willful non-compliance. This is why monitoring FinCEN.gov matters.
Do I need to file a BOI report for a Texas LLC formed in 2026?
No, not under the current rules. The March 2025 interim final rule exempts all domestic entities, including those newly formed. As always, verify against fincen.gov/boi before concluding you have no obligation — rules can change.
I filed a BOI report before the exemption — do I need to do anything?
No action required. Your previously filed report is on record with FinCEN. There is no process to "unfile" or withdraw it, and there is no penalty for having filed. If the rules are reinstated in the future, any prior filing may reduce your compliance burden.
Is the BOI exemption permanent?
No. The March 21, 2025 interim final rule is the current regulatory state, but "interim" means it can be revised. It reflects an administrative policy decision that could change with a new rule, court ruling, or Congressional action. Treat it as current but not guaranteed, and check FinCEN.gov at least annually.
Does the BOI exemption affect my Texas state filings?
No. The BOI report is a federal requirement (FinCEN). It has no connection to Texas franchise tax, the Public Information Report, or any other Texas state filing. Your state obligations remain the same regardless of BOI status. See the Texas LLC annual filing checklist for what you still owe to the state.
Not sure what else your Texas LLC owes?
Most business owners are surprised by how many filing obligations they have. Ortholo's free compliance checker shows you everything you owe, when it's due, and what happens if you miss it — personalized to your entity.
Check my obligations — free →Last verified: 2026-04-27