Washington corporate transparency requirements

Summary for Washington business owners and LLC founders — current status (as of 2026-01-03) and practical compliance guidance:1) Current legal status (federal):- FinCEN’s March 26, 2025 interim final rule (IFR) narrowed the definition of “reporting company” under the Corporate Transparency Act (CTA) so that domestic U.S. entities (entities created in the United States, previously called “domestic reporting companies”) and their beneficial owners are exempt from the BOI reporting requirement.

Only certain foreign-formed entities that have registered to do business in the U.S. remain subject to BOI reporting. (See FinCEN citations below).- Deadlines in the IFR for foreign reporting companies: entities registered to do business in the U.S. before March 26, 2025 had until April 25, 2025 to file; entities registered on/after March 26, 2025 have 30 calendar days after notice that registration is effective to file. (FinCEN)- FinCEN continues to provide guidance, filing resources, and e‑filing at its BOI portal; there is no fee to file, and FinCEN warns of scams.

Although enforcement against domestic companies was paused and the IFR exempts domestic entities, the regulatory landscape has been dynamic; monitor FinCEN/Treasury updates. 2) Washington-specific status and interaction with state filings:- Washington State guidance (WA Secretary of State and business.wa.gov) reflects the FinCEN IFR: the BOI report is no longer required for domestic reporting companies effective March 26, 2025; Washington has not enacted a separate state-level BOI reporting requirement.

The Washington Secretary of State continues to require state filings like annual reports, registered agent maintenance, and updates to business entity records, but these are separate from FinCEN’s BOI reporting. - Practical implication: if your entity was formed in Washington (a “domestic” WA entity), you currently do not need to file BOI with FinCEN because of the IFR, but you must continue to comply with all Washington state filing and tax obligations (Secretary of State annual reports, Dept. of Revenue registrations, etc.).

If your entity was formed under foreign law and registered in Washington (a “foreign” entity), it may still be a reporting company under the CTA and could have been subject to FinCEN deadlines (see IFR deadlines). 3) What Washington business owners and LLC founders should do now (recommended checklist):- Maintain and centralize ownership records: collect and securely store each owner and controlling person’s legal name, date of birth, current address, government ID number and image (passport/driver’s license), and supporting documentation.

Even if you are currently exempt, these materials will speed compliance if rules change.- Review entity status: confirm whether your entity is “domestic” (formed in the U.S./Washington) or “foreign” (formed abroad and registered in WA).

Foreign-formed entities registered in the U.S. remain the primary group potentially required to file BOI per the IFR.- Check exemptions: review the CTA’s 23 exempt entity types (e.g., many regulated financial institutions, SEC-reporting companies, large operating companies, inactive entities) to see if your business qualifies for an exemption.- Keep state filings current: continue to file Washington annual reports and keep the Secretary of State records (principal office, registered agent, officers/managers where applicable) up to date.

The CTA/FinCEN reporting does not replace state filings.- Watch for federal changes and enforcement updates: the CTA/FinCEN rulemaking and litigation history has been fluid (injunctions, non-enforcement notices, IFR).

Subscribe to FinCEN updates and check the Washington SOS/business.wa.gov pages periodically.- Avoid scams and third-party solicitations: FinCEN does not charge a fee to file BOI; beware solicitations demanding payment or requesting sensitive information by email/links.

Use the FinCEN BOI e-filing portal if filing is required.- If unsure, seek counsel: because the substantive definitions (e.g., “substantial control,” indirect ownership) can be complex, consult an attorney or CPA to determine reporting obligations and to prepare filings if required.4) Filing mechanics and resources (if filing becomes required):- File through FinCEN’s BOI e-filing system: https://boiefiling.fincen.gov/fileboir .

FinCEN provides filing instructions, quick-reference guides, and a Small Entity Compliance Guide.- What is typically required in a BOI report (histor practice under CTA rules): company identifying info (legal name, DBAs, principal office address, jurisdiction of formation, TIN/EIN) and for each beneficial owner or company applicant: full legal name, date of birth, current address, an identifying number and image from a non-expired passport, state driver’s license or other acceptable ID. (FinCEN resources explain company applicants apply to entities created/registered on/after Jan 1, 2024.)- Penalties (histor/possible): the CTA historically provided civil penalties (up to $500 per day) and criminal penalties (fines up to $10,000 and imprisonment up to 2 years) for willful violations; however, enforcement against domestic entities has been paused/altered by recent rulemaking and court actions—still, these statutory penalties remain part of the legal framework if enforcement posture changes.5) Bottom line for Washington business owners / LLC founders:- If your entity was formed in Washington (a domestic U.S. entity), FinCEN’s March 26, 2025 IFR currently exempts you from filing BOI with FinCEN.

Nonetheless, maintain accurate ownership records, keep Washington state filings and Dept. of Revenue registrations current, and monitor federal rulemaking and guidance. - If your entity was formed outside the U.S. (foreign entity) and registered to do business in Washington, you may have been required to file BOI under the IFR timeline—check FinCEN’s portal and guidance and consult counsel if you have not yet filed.

Summary for Washington business owners and LLC founders — current status (as of 2026-01-03) and practical compliance guidance:1) Current legal status (federal):- FinCEN’s March 26, 2025 interim final rule (IFR) narrowed the definition of “reporting company” under the Corporate Transparency Act (CTA) so that domestic U.S. entities (entities created in the United States, previously called “domestic reporting companies”) and their beneficial owners are exempt from the BOI reporting requirement.

Only certain foreign-formed entities that have registered to do business in the U.S. remain subject to BOI reporting. (See FinCEN citations below).- Deadlines in the IFR for foreign reporting companies: entities registered to do business in the U.S. before March 26, 2025 had until April 25, 2025 to file; entities registered on/after March 26, 2025 have 30 calendar days after notice that registration is effective to file. (FinCEN)- FinCEN continues to provide guidance, filing resources, and e‑filing at its BOI portal; there is no fee to file, and FinCEN warns of scams.

Although enforcement against domestic companies was paused and the IFR exempts domestic entities, the regulatory landscape has been dynamic; monitor FinCEN/Treasury updates. 2) Washington-specific status and interaction with state filings:- Washington State guidance (WA Secretary of State and business.wa.gov) reflects the FinCEN IFR: the BOI report is no longer required for domestic reporting companies effective March 26, 2025; Washington has not enacted a separate state-level BOI reporting requirement.

The Washington Secretary of State continues to require state filings like annual reports, registered agent maintenance, and updates to business entity records, but these are separate from FinCEN’s BOI reporting.

3) What Washington business owners and LLC founders should do now (recommended checklist):- Maintain and centralize ownership records: collect and securely store each owner and controlling person’s legal name, date of birth, current address, government ID number and image (passport/driver’s license), and supporting documentation.

Even if you are currently exempt, these materials will speed compliance if rules change.- Review entity status: confirm whether your entity is “domestic” (formed in the U.S./Washington) or “foreign” (formed abroad and registered in WA).

Foreign-formed entities registered in the U.S. remain the primary group potentially required to file BOI per the IFR.- Check exemptions: review the CTA’s 23 exempt entity types (e.g., many regulated financial institutions, SEC-reporting companies, large operating companies, inactive entities) to see if your business qualifies for an exemption.- Keep state filings current: continue to file Washington annual reports and keep the Secretary of State records (principal office, registered agent, officers/managers where applicable) up to date.

The CTA/FinCEN reporting does not replace state filings.- Watch for federal changes and enforcement updates: the CTA/FinCEN rulemaking and litigation history has been fluid (injunctions, non-enforcement notices, IFR).

Subscribe to FinCEN updates and check the Washington SOS/business.wa.gov pages periodically.- Avoid scams and third-party solicitations: FinCEN does not charge a fee to file BOI; beware solicitations demanding payment or requesting sensitive information by email/links.

Use the FinCEN BOI e-filing portal if filing is required.- If unsure, seek counsel: because the substantive definitions (e.g., “substantial control,” indirect ownership) can be complex, consult an attorney or CPA to determine reporting obligations and to prepare filings if required.4) Filing mechanics and resources (if filing becomes required):- File through FinCEN’s BOI e-filing system: https://boiefiling.fincen.gov/fileboir .

FinCEN provides filing instructions, quick-reference guides, and a Small Entity Compliance Guide.- What is typically required in a BOI report (histor practice under CTA rules): company identifying info (legal name, DBAs, principal office address, jurisdiction of formation, TIN/EIN) and for each beneficial owner or company applicant: full legal name, date of birth, current address, an identifying number and image from a non-expired passport, state driver’s license or other acceptable ID. (FinCEN resources explain company applicants apply to entities created/registered on/after Jan 1, 2024.)- Penalties (histor/possible): the CTA historically provided civil penalties (up to $500 per day) and criminal penalties (fines up to $10,000 and imprisonment up to 2 years) for willful violations; however, enforcement against domestic entities has been paused/altered by recent rulemaking and court actions—still, these statutory penalties remain part of the legal framework if enforcement posture changes.5) Bottom line for Washington business owners / LLC founders:- If your entity was formed in Washington (a domestic U.S. entity), FinCEN’s March 26, 2025 IFR currently exempts you from filing BOI with FinCEN.

Nonetheless, maintain accurate ownership records, keep Washington state filings and Dept. of Revenue registrations current, and monitor federal rulemaking and guidance.

• Practical implication: if your entity was formed in Washington (a “domestic” WA entity), you currently do not need to file BOI with FinCEN because of the IFR, but you must continue to comply with all Washington state filing and tax obligations (Secretary of State annual reports, Dept. of Revenue registrations, etc.). If your entity was formed under foreign law and registered in Washington (a “foreign” entity), it may still be a reporting company under the CTA and could have been subject to FinCEN deadlines (see IFR deadlines).
• If your entity was formed outside the U.S. (foreign entity) and registered to do business in Washington, you may have been required to file BOI under the IFR timeline—check FinCEN’s portal and guidance and consult counsel if you have not yet filed.