Department of Treasury Finalizes Corporate Transparency Act Reporting Rollback

On August 11, 2026, the U.S. Department of Treasury's Financial Crimes Enforcement Network (FinCEN) published a Final Rule to permanently exempt small businesses including cooperatives from Beneficial Ownership Information (BOI) reporting under the Corporate Transparency Act (CTA). The final rule makes permanent changes first adopted on an interim basis in March 2025.

Under the original CTA reporting rule, many cooperatives were required to report administratively burdensome identifying information about beneficial owners, including board directors, senior officers or general managers, to FinCEN. NCBA previously shared an update on court challenges that temporarily suspended those requirements in late 2024 and early 2025.

The Final Rule:

• Permanently exempts U.S. persons who have obtained FinCEN IDs from any obligation to update or correct the information they may have originally provided to FinCEN to obtain their FinCEN IDs;
• Eliminates the requirement for foreign companies to report individuals who helped those foreign companies register to do business in the United States);
• Exempts foreign pooled investment vehicles registered in the United States from reporting the beneficial ownership information of a U.S person in control of the investment vehicle; and
• Confirms that FinCEN will delete information about any individuals-company applicants, beneficial owners, or recipients of a FinCEN ID-that FinCEN reasonably believes is a U.S. person (e.g., the information is linked to a U.S. passport or U.S. driver's license).

Overview of the CTA

The CTA became law in 2021, and its BOI reporting requirements took effect in January 2024. Litigation challenging the law later resulted in nationwide injunctions that paused implementation and reporting deadlines.

In March 2025, FinCen announced that it would no longer enforce the CTA against U.S. citizens and domestic reporting companies and later issued an interim final rule issued an interim final rule formally exempting domestic small businesses, including cooperatives. FinCEN's final rule now makes that exemption permanent under the agency's regulations.

What does this mean for cooperatives?

For cooperatives organized in the United States, the final rule means they are no longer required to file beneficial ownership information reports with FinCEN or update or correct previously filed BOI reports.

FinCEN also plans to remove from its beneficial ownership database information previously submitted by U.S. companies and U.S. persons and does not anticipate requiring companies or individuals to request that their information be removed.

NCBA will continue to monitor developments and keep members informed of any future changes affecting cooperative businesses. To learn more about the CTA's impact on cooperatives, you may view NCBA CLUSA updates here and receive email updates from Treasury's FinCEN here.