Last updated: October 7, 2026
Does your Maryland business still need to file a beneficial ownership information report under the Corporate Transparency Act?
Companies created in the United States—including Maryland LLCs and corporations—are now exempt from federal BOI reporting. Certain companies formed under foreign-country laws and registered to do business in the United States still have reporting obligations.
FinCEN announced its final rule on August 11, 2026, confirming the exemption for U.S. companies and U.S. persons while retaining reporting requirements for covered foreign entities. Read FinCEN’s announcement.
Corporate Transparency Act Timeline: Key Dates
January 1, 2024: BOI Reporting Began
FinCEN’s original reporting framework took effect on January 1, 2024. Under that framework, covered companies created or registered during 2024 generally had 90 calendar days after receiving actual or public notice of their creation or registration to submit their initial report.
January 1, 2025, was the original deadline for covered entities created or registered before 2024. These dates explain the earlier reporting framework; they should not be treated as current filing instructions for exempt U.S. companies. FinCEN’s historical reporting guidance
March 26, 2025: Domestic Companies Became Exempt
FinCEN published an interim final rule narrowing the reporting requirements to qualifying foreign entities. Companies created in the United States became exempt.
For foreign entities still required to report, the rule generally established:
April 25, 2025: The initial reporting deadline for companies registered to do business in the United States before March 26, 2025.
A 30-calendar-day filing period: For companies registered on or after March 26, 2025.
The April 2025 deadline has already passed. It is a historical deadline, not an upcoming filing date. FinCEN’s reporting update
August 14, 2026: The Final Rule Took Effect
The final rule preserved the domestic-company exemption and added protections for U.S. persons. Among other changes, it exempted U.S. person company applicants from reporting and removed obligations for U.S. persons to update or correct information previously submitted to obtain a FinCEN identifier. Read the final rule
Which Companies Still Need to Report?
A company generally remains subject to BOI reporting if it:
Was formed under the law of a foreign country.
Registered to do business in a U.S. state or Tribal jurisdiction by filing with a secretary of state or similar office.
Does not qualify for another reporting exemption.
For this purpose, “foreign” refers to formation under another country’s laws. An LLC created in Delaware and registered in Maryland is still a U.S.-created entity.
The company’s place of formation matters: foreign ownership alone does not make a U.S.-created company a foreign reporting company. FinCEN’s explanation of reporting-company coverage
Current Deadlines for Covered Foreign Companies
A covered foreign company registered on or after March 26, 2025, generally must file its initial report within 30 calendar days of the earlier of actual notice or public notice that its registration is effective. FinCEN’s deadline explanation
Companies that remain subject to reporting also generally must:
Update required company or beneficial-owner information within 30 days of a change.
Correct inaccurate information within 30 days after becoming aware of it or having reason to know of it.
These continuing obligations apply to information that remains reportable under the current rules. FinCEN’s update and correction guidance
Reporting companies do not need to report information about U.S. person beneficial owners or U.S. person company applicants. FinCEN’s current reference materials
What If Your Maryland LLC Already Filed?
A U.S.-created company does not need to continue updating or correcting its previous BOI report under the domestic-company exemption. Filing a report before the rules changed does not create a continuing reporting obligation for an otherwise exempt domestic entity. Final rule and explanation of the domestic exemption
For example, an LLC formed under Maryland law in March 2024 is now exempt from federal BOI reporting. Its owner should not rely on older articles stating that every ownership change requires a new FinCEN filing.
Get Help Understanding Your Business’s Obligations
Before relying on an old CTA deadline reminder, confirm where your company was formed and whether it falls within the current reporting rules.
DK Law Group helps business owners understand how legal requirements affect their companies. If you have questions about your entity’s status or business compliance, contact DK Law Group to discuss your circumstances.
This article provides general information and is not legal advice for a specific business.
