BOI compliance for online retailers

BOI compliance for online retailers Current status (as of 2026-01-03): FinCEN’s March 26, 2025 interim final rule narrowed the CTA/BOI reporting scope so that domestic entities formed under U.S. law (including most U.S.

LLCs and online retailers) and U.S. persons are exempt from filing BOI reports with FinCEN. The rule retains BOI reporting obligations primarily for certain foreign entities that register to do business in U.S. states ("foreign reporting companies").

Deadlines (foreign reporting companies): Entities registered to do business in the U.S. before March 26, 2025 had to file by April 25, 2025; entities registered on or after March 26, 2025 have 30 calendar days from registration becoming effective to file an initial BOI report.

Reporting/updates/corrections generally must be filed within 30 days of a change. FinCEN continues to accept comments and may issue a final rule.

What was previously required (important operational notes): Under the original CTA/Reporting Rule (effective Jan 1, 2024), reporting companies generally had to provide identifying information about the reporting company (e.g., name, EIN), each beneficial owner (name, date of birth, address, identifying number such as driver’s license or passport), and, for companies formed/registered on/after Jan 1, 2024, company applicant(s).

That remains the structure FinCEN preserved for foreign reporting companies under the interim final rule (except U.S. persons need not be reported). Knowing what would be required remains useful for domestic companies preparing records.

Practical takeaways for US online retailers / LLC founders: 1) Most U.S. online retailers organized in the U.S. currently do NOT need to file BOI with FinCEN due to the March 26, 2025 interim final rule.

However, this is an interim rule and subject to comment and possible future revision — monitor FinCEN and Treasury announcements. Current status (as of 2026-01-03): FinCEN’s March 26, 2025 interim final rule narrowed the CTA/BOI reporting scope so that domestic entities formed under U.S. law (including most U.S.

LLCs and online retailers) and U.S. persons are exempt from filing BOI reports with FinCEN. The rule retains BOI reporting obligations primarily for certain foreign entities that register to do business in U.S. states ("foreign reporting companies").

Deadlines (foreign reporting companies): Entities registered to do business in the U.S. before March 26, 2025 had to file by April 25, 2025; entities registered on or after March 26, 2025 have 30 calendar days from registration becoming effective to file an initial BOI report.

Reporting/updates/corrections generally must be filed within 30 days of a change. FinCEN continues to accept comments and may issue a final rule.

What was previously required (important operational notes): Under the original CTA/Reporting Rule (effective Jan 1, 2024), reporting companies generally had to provide identifying information about the reporting company (e.g., name, EIN), each beneficial owner (name, date of birth, address, identifying number such as driver’s license or passport), and, for companies formed/registered on/after Jan 1, 2024, company applicant(s).

That remains the structure FinCEN preserved for foreign reporting companies under the interim final rule (except U.S. persons need not be reported). Knowing what would be required remains useful for domestic companies preparing records.

Practical takeaways for US online retailers / LLC founders: 1) Most U.S. online retailers organized in the U.S. currently do NOT need to file BOI with FinCEN due to the March 26, 2025 interim final rule.

However, this is an interim rule and subject to comment and possible future revision — monitor FinCEN and Treasury announcements. Maintain complete internal BOI records keep up-to-date records of owners, managers, controllers, company applicant(s), and identity documents (name, DOB, address, identifying number).

This reduces future compliance burden if the rule changes and helps with third-party onboarding (banks, marketplaces). If you are a foreign entity (formed outside the U.S.) that has registered to do business in any U.S. state, verify whether you qualify as a "foreign reporting company" — if so, follow the filing deadlines (30 days for post-March-26-2025 registrations; earlier registrants had April 25, 2025 deadline) and report required non-U.S. beneficial owners per the rule.

Single-member LLCs and sole owners historically they would be the beneficial owner and data required would include name, DOB, address, and ID number — domestic exemption means you likely do not need to file now but keep records.

Marketplace/platform onboarding and banks many platforms and financial institutions conduct their own identity/beneficial-owner checks; you may need to provide similar BOI data to them even if you are exempt from filing with FinCEN.

Penalties and enforcement BOI reporting under the CTA originally carried civil and criminal penalties for willful failures to report or willful filing of false information; while domestic entities are currently exempt under the interim final rule, be aware of statutory penalties if obligations are reinstated for your entity in future rulemaking.

Monitor FinCEN guidance for enforcement posture. BOI compliance for online retailers Current status (as of 2026-01-03): FinCEN’s March 26, 2025 interim final rule narrowed the CTA/BOI reporting scope so that domestic entities formed under U.S. law (including most U.S.

LLCs and online retailers) and U.S. persons are exempt from filing BOI reports with FinCEN. The rule retains BOI reporting obligations primarily for certain foreign entities that register to do business in U.S. states ("foreign reporting companies").

Deadlines (foreign reporting companies): Entities registered to do business in the U.S. before March 26, 2025 had to file by April 25, 2025; entities registered on or after March 26, 2025 have 30 calendar days from registration becoming effective to file an initial BOI report.

Reporting/updates/corrections generally must be filed within 30 days of a change. FinCEN continues to accept comments and may issue a final rule.

What was previously required (important operational notes): Under the original CTA/Reporting Rule (effective Jan 1, 2024), reporting companies generally had to provide identifying information about the reporting company (e.g., name, EIN), each beneficial owner (name, date of birth, address, identifying number such as driver’s license or passport), and, for companies formed/registered on/after Jan 1, 2024, company applicant(s).

That remains the structure FinCEN preserved for foreign reporting companies under the interim final rule (except U.S. persons need not be reported). Knowing what would be required remains useful for domestic companies preparing records.

Practical takeaways for US online retailers / LLC founders: 1) Most U.S. online retailers organized in the U.S. currently do NOT need to file BOI with FinCEN due to the March 26, 2025 interim final rule.

However, this is an interim rule and subject to comment and possible future revision — monitor FinCEN and Treasury announcements. Current status (as of 2026-01-03): FinCEN’s March 26, 2025 interim final rule narrowed the CTA/BOI reporting scope so that domestic entities formed under U.S. law (including most U.S.

LLCs and online retailers) and U.S. persons are exempt from filing BOI reports with FinCEN. The rule retains BOI reporting obligations primarily for certain foreign entities that register to do business in U.S. states ("foreign reporting companies").

Deadlines (foreign reporting companies): Entities registered to do business in the U.S. before March 26, 2025 had to file by April 25, 2025; entities registered on or after March 26, 2025 have 30 calendar days from registration becoming effective to file an initial BOI report.

Reporting/updates/corrections generally must be filed within 30 days of a change. FinCEN continues to accept comments and may issue a final rule.

What was previously required (important operational notes): Under the original CTA/Reporting Rule (effective Jan 1, 2024), reporting companies generally had to provide identifying information about the reporting company (e.g., name, EIN), each beneficial owner (name, date of birth, address, identifying number such as driver’s license or passport), and, for companies formed/registered on/after Jan 1, 2024, company applicant(s).

That remains the structure FinCEN preserved for foreign reporting companies under the interim final rule (except U.S. persons need not be reported). Knowing what would be required remains useful for domestic companies preparing records.

Practical takeaways for US online retailers / LLC founders: 1) Most U.S. online retailers organized in the U.S. currently do NOT need to file BOI with FinCEN due to the March 26, 2025 interim final rule.

However, this is an interim rule and subject to comment and possible future revision — monitor FinCEN and Treasury announcements. Maintain complete internal BOI records keep up-to-date records of owners, managers, controllers, company applicant(s), and identity documents (name, DOB, address, identifying number).

This reduces future compliance burden if the rule changes and helps with third-party onboarding (banks, marketplaces). If you are a foreign entity (formed outside the U.S.) that has registered to do business in any U.S. state, verify whether you qualify as a "foreign reporting company" — if so, follow the filing deadlines (30 days for post-March-26-2025 registrations; earlier registrants had April 25, 2025 deadline) and report required non-U.S. beneficial owners per the rule.

Single-member LLCs and sole owners historically they would be the beneficial owner and data required would include name, DOB, address, and ID number — domestic exemption means you likely do not need to file now but keep records.

Marketplace/platform onboarding and banks many platforms and financial institutions conduct their own identity/beneficial-owner checks; you may need to provide similar BOI data to them even if you are exempt from filing with FinCEN.

Penalties and enforcement BOI reporting under the CTA originally carried civil and criminal penalties for willful failures to report or willful filing of false information; while domestic entities are currently exempt under the interim final rule, be aware of statutory penalties if obligations are reinstated for your entity in future rulemaking.

Monitor FinCEN guidance for enforcement posture.

BOI compliance for online retailers Current status (as of 2026-01-03): FinCEN’s March 26, 2025 interim final rule narrowed the CTA/BOI reporting scope so that domestic entities formed under U.S. law (including most U.S.

LLCs and online retailers) and U.S. persons are exempt from filing BOI reports with FinCEN. The rule retains BOI reporting obligations primarily for certain foreign entities that register to do business in U.S. states ("foreign reporting companies").

Deadlines (foreign reporting companies): Entities registered to do business in the U.S. before March 26, 2025 had to file by April 25, 2025; entities registered on or after March 26, 2025 have 30 calendar days from registration becoming effective to file an initial BOI report.

Reporting/updates/corrections generally must be filed within 30 days of a change. FinCEN continues to accept comments and may issue a final rule.

What was previously required (important operational notes): Under the original CTA/Reporting Rule (effective Jan 1, 2024), reporting companies generally had to provide identifying information about the reporting company (e.g., name, EIN), each beneficial owner (name, date of birth, address, identifying number such as driver’s license or passport), and, for companies formed/registered on/after Jan 1, 2024, company applicant(s).

That remains the structure FinCEN preserved for foreign reporting companies under the interim final rule (except U.S. persons need not be reported). Knowing what would be required remains useful for domestic companies preparing records.

Practical takeaways for US online retailers / LLC founders: 1) Most U.S. online retailers organized in the U.S. currently do NOT need to file BOI with FinCEN due to the March 26, 2025 interim final rule.

However, this is an interim rule and subject to comment and possible future revision — monitor FinCEN and Treasury announcements. Current status (as of 2026-01-03): FinCEN’s March 26, 2025 interim final rule narrowed the CTA/BOI reporting scope so that domestic entities formed under U.S. law (including most U.S.

LLCs and online retailers) and U.S. persons are exempt from filing BOI reports with FinCEN. The rule retains BOI reporting obligations primarily for certain foreign entities that register to do business in U.S. states ("foreign reporting companies").

Deadlines (foreign reporting companies): Entities registered to do business in the U.S. before March 26, 2025 had to file by April 25, 2025; entities registered on or after March 26, 2025 have 30 calendar days from registration becoming effective to file an initial BOI report.

Reporting/updates/corrections generally must be filed within 30 days of a change. FinCEN continues to accept comments and may issue a final rule.

What was previously required (important operational notes): Under the original CTA/Reporting Rule (effective Jan 1, 2024), reporting companies generally had to provide identifying information about the reporting company (e.g., name, EIN), each beneficial owner (name, date of birth, address, identifying number such as driver’s license or passport), and, for companies formed/registered on/after Jan 1, 2024, company applicant(s).

That remains the structure FinCEN preserved for foreign reporting companies under the interim final rule (except U.S. persons need not be reported). Knowing what would be required remains useful for domestic companies preparing records.

Practical takeaways for US online retailers / LLC founders: 1) Most U.S. online retailers organized in the U.S. currently do NOT need to file BOI with FinCEN due to the March 26, 2025 interim final rule.

However, this is an interim rule and subject to comment and possible future revision — monitor FinCEN and Treasury announcements. Maintain complete internal BOI records keep up-to-date records of owners, managers, controllers, company applicant(s), and identity documents (name, DOB, address, identifying number).

This reduces future compliance burden if the rule changes and helps with third-party onboarding (banks, marketplaces). If you are a foreign entity (formed outside the U.S.) that has registered to do business in any U.S. state, verify whether you qualify as a "foreign reporting company" — if so, follow the filing deadlines (30 days for post-March-26-2025 registrations; earlier registrants had April 25, 2025 deadline) and report required non-U.S. beneficial owners per the rule.

Single-member LLCs and sole owners historically they would be the beneficial owner and data required would include name, DOB, address, and ID number — domestic exemption means you likely do not need to file now but keep records.

Marketplace/platform onboarding and banks many platforms and financial institutions conduct their own identity/beneficial-owner checks; you may need to provide similar BOI data to them even if you are exempt from filing with FinCEN.

Penalties and enforcement BOI reporting under the CTA originally carried civil and criminal penalties for willful failures to report or willful filing of false information; while domestic entities are currently exempt under the interim final rule, be aware of statutory penalties if obligations are reinstated for your entity in future rulemaking.

Monitor FinCEN guidance for enforcement posture. BOI compliance for online retailers Current status (as of 2026-01-03): FinCEN’s March 26, 2025 interim final rule narrowed the CTA/BOI reporting scope so that domestic entities formed under U.S. law (including most U.S.

LLCs and online retailers) and U.S. persons are exempt from filing BOI reports with FinCEN. The rule retains BOI reporting obligations primarily for certain foreign entities that register to do business in U.S. states ("foreign reporting companies").

Deadlines (foreign reporting companies): Entities registered to do business in the U.S. before March 26, 2025 had to file by April 25, 2025; entities registered on or after March 26, 2025 have 30 calendar days from registration becoming effective to file an initial BOI report.

Reporting/updates/corrections generally must be filed within 30 days of a change. FinCEN continues to accept comments and may issue a final rule.

What was previously required (important operational notes): Under the original CTA/Reporting Rule (effective Jan 1, 2024), reporting companies generally had to provide identifying information about the reporting company (e.g., name, EIN), each beneficial owner (name, date of birth, address, identifying number such as driver’s license or passport), and, for companies formed/registered on/after Jan 1, 2024, company applicant(s).

That remains the structure FinCEN preserved for foreign reporting companies under the interim final rule (except U.S. persons need not be reported). Knowing what would be required remains useful for domestic companies preparing records.

Practical takeaways for US online retailers / LLC founders: 1) Most U.S. online retailers organized in the U.S. currently do NOT need to file BOI with FinCEN due to the March 26, 2025 interim final rule.

However, this is an interim rule and subject to comment and possible future revision — monitor FinCEN and Treasury announcements. Current status (as of 2026-01-03): FinCEN’s March 26, 2025 interim final rule narrowed the CTA/BOI reporting scope so that domestic entities formed under U.S. law (including most U.S.

LLCs and online retailers) and U.S. persons are exempt from filing BOI reports with FinCEN. The rule retains BOI reporting obligations primarily for certain foreign entities that register to do business in U.S. states ("foreign reporting companies").

Deadlines (foreign reporting companies): Entities registered to do business in the U.S. before March 26, 2025 had to file by April 25, 2025; entities registered on or after March 26, 2025 have 30 calendar days from registration becoming effective to file an initial BOI report.

Reporting/updates/corrections generally must be filed within 30 days of a change. FinCEN continues to accept comments and may issue a final rule.

What was previously required (important operational notes): Under the original CTA/Reporting Rule (effective Jan 1, 2024), reporting companies generally had to provide identifying information about the reporting company (e.g., name, EIN), each beneficial owner (name, date of birth, address, identifying number such as driver’s license or passport), and, for companies formed/registered on/after Jan 1, 2024, company applicant(s).

That remains the structure FinCEN preserved for foreign reporting companies under the interim final rule (except U.S. persons need not be reported). Knowing what would be required remains useful for domestic companies preparing records.

Practical takeaways for US online retailers / LLC founders: 1) Most U.S. online retailers organized in the U.S. currently do NOT need to file BOI with FinCEN due to the March 26, 2025 interim final rule.

However, this is an interim rule and subject to comment and possible future revision — monitor FinCEN and Treasury announcements. Maintain complete internal BOI records keep up-to-date records of owners, managers, controllers, company applicant(s), and identity documents (name, DOB, address, identifying number).

This reduces future compliance burden if the rule changes and helps with third-party onboarding (banks, marketplaces). If you are a foreign entity (formed outside the U.S.) that has registered to do business in any U.S. state, verify whether you qualify as a "foreign reporting company" — if so, follow the filing deadlines (30 days for post-March-26-2025 registrations; earlier registrants had April 25, 2025 deadline) and report required non-U.S. beneficial owners per the rule.

Single-member LLCs and sole owners historically they would be the beneficial owner and data required would include name, DOB, address, and ID number — domestic exemption means you likely do not need to file now but keep records.

Marketplace/platform onboarding and banks many platforms and financial institutions conduct their own identity/beneficial-owner checks; you may need to provide similar BOI data to them even if you are exempt from filing with FinCEN.

Penalties and enforcement BOI reporting under the CTA originally carried civil and criminal penalties for willful failures to report or willful filing of false information; while domestic entities are currently exempt under the interim final rule, be aware of statutory penalties if obligations are reinstated for your entity in future rulemaking.

Monitor FinCEN guidance for enforcement posture.