Foreign entities registered to do business in the U.S. are still required to file a BOI, but modifications have been made for those companies as well. There is no longer the need to report U.S. beneficial owners. Foreign entities are now not required to disclose the BOI of U.S. beneficial owners and U.S. citizens are now not required to report their ownership information. The new rule also allows that if a foreign reporting company only has beneficial owners that are U.S. persons, then the company is exempt from reporting BOI. 

Under the CTA, an individual qualifies as a beneficial owner if they directly or indirectly have a significant ownership stake in a company. They are considered a beneficial owner if they have significant influence on the reporting company’s decisions or operations, own at least 25% of the company's shares, or have a similar level of control over the company's equity. Information such as full legal name, date of birth, home address, and a form of identification such as a driver’s license or passport may be required. Companies formed after January 1, 2025 have 30 calendar days from their creation or registration date to file.

No annual reporting is required. Companies will need to submit updates to their original filing when there are changes within their business, such as a beneficial owner changing their address or name, or reallocation of management responsibilities within the business.