Do Landlords Still Need to File a BOI Report?

Do Landlords Still Need to File a BOI Report?

No. If your rental business is a US-formed LLC, you are permanently exempt from beneficial ownership information reporting. FinCEN finalised that exemption on 14 August 2026, and it has not been enforced against US companies since March 2025.

If you landed here from older advice telling you to file or face penalties, that advice is out of date. Here is what changed, when, and what it means if you already filed.

What the requirement used to be

The Corporate Transparency Act created a reporting regime aimed at shell companies used for money laundering. From 1 January 2024, most US corporations, LLCs and similar entities had to send FinCEN details of their beneficial owners.

A beneficial owner was any individual who either exercised substantial control over the company, or owned or controlled at least 25% of it. Twenty-three categories of entity were exempt, but they were mostly banks, insurers, public utilities and large operating companies. A landlord holding a few rentals in an LLC qualified for none of them.

That is why the original version of this article told landlords to file a report for each LLC. At the time, it was correct.

Two things in that original guidance were wrong even then, and they are worth correcting for the record. BOI reports were always filed with FinCEN, not the IRS, and the filing system opened on 1 January 2024 rather than remaining unavailable. If you read this page in its earlier form and acted on either point, neither affects you now, because the obligation itself is gone.

What changed, and when?

The regime was contested almost immediately, and the sequence matters if you are trying to work out whether you missed something.

Four months of on-again, off-again deadlines over the 2024 holidays is why so much conflicting advice is still circulating. If you saw a filing deadline in early 2025 and panicked, that deadline was real at the time. It no longer applies to you.

Who still has to file?

The final rule did not repeal the Corporate Transparency Act. It narrowed who counts as a reporting company.

An entity still reports if it was formed under the law of a foreign country and has registered to do business in a US state or tribal jurisdiction by filing with a secretary of state or equivalent office, and does not qualify for one of the exemptions.

Even then, it only reports its non-US-person beneficial owners. A foreign entity whose owners are all US persons reports no individuals at all.

Current deadlines for those entities are 30 calendar days after receiving notice that the registration is effective. Entities that registered before 26 March 2025 had until 25 April 2025.

For most US landlords this is academic. It becomes relevant if you hold US rental property through an entity formed offshore, which is uncommon for individual investors and worth a conversation with your attorney if it describes you.

If you already filed

You do not need to do anything, and there is nothing to withdraw.

FinCEN has said it will delete previously reported information belonging to US persons from the beneficial ownership database. The obligation to update or correct information within 30 days of a change, which applied under the original rule, no longer applies to US persons. If you obtained a FinCEN identifier, you are not required to keep it current.

What this does not change

The exemption is narrow. It removes one federal filing. It does not touch anything else about how you hold or run your rentals.

• Your state filings still apply. Annual reports, franchise taxes and registered agent requirements are set by the state your LLC is registered in, and none of them changed.
• An LLC is still worth considering for liability separation and how your rental income is taxed. If you are weighing it up, our guides on whether to form an LLC for your rentals and how to structure your real estate business cover the trade-offs.
• Your records still matter. Knowing who owns what, and keeping the paperwork to prove it, is what makes tax time and any future financing straightforward, regardless of what FinCEN asks for.

Frequently asked questions

Was the Corporate Transparency Act repealed?

No. The Act is still law. FinCEN changed the definition of "reporting company" so that it covers only foreign-formed entities registered to do business in the US.

Could this change back?

The August 2026 rule is final rather than interim, which makes it considerably more settled than the position through 2025. It could be revisited by a future rulemaking or by Congress. We will update this page if it is.

I never filed and I was supposed to. Am I in trouble?

‍FinCEN stopped enforcing penalties against US citizens and domestic reporting companies from March 2025, and those entities are now exempt outright. If you have a specific concern about your own position, speak to your attorney rather than relying on this page.

Do I need to tell FinCEN my LLC is exempt?

No. There is no exemption filing.

‍

‍

‍