Does a Rental Property LLC Have to File a BOI Report in 2026?
No: FinCEN’s August 2026 final rule exempts companies created in the U.S. from beneficial ownership reporting. What changed, and who still has to file.
By Seayora Editorial Team · Published · Facts checked · 2 min read
Short answer: No. Under FinCEN’s final rule issued August 11, 2026 and effective August 14, 2026, companies created in the United States, including the LLCs most landlords use to hold rental property, are not reporting companies under the Corporate Transparency Act and do not file beneficial ownership information reports. Only companies formed under foreign law and registered to do business in a U.S. state still report.
Key takeaways
- A domestic LLC, corporation or limited partnership that holds rentals does not file a BOI report.
- The exemption began with an interim final rule on March 26, 2025 and was made permanent in August 2026.
- FinCEN said it will delete information previously reported by U.S. persons.
- State LLC filings, annual reports and registered-agent requirements are unaffected.
What changed?
The Corporate Transparency Act required most small companies to report their beneficial owners to FinCEN starting in 2024. On March 26, 2025 FinCEN issued an interim final rule narrowing “reporting company” to entities formed under the law of a foreign country (interim final rule, March 26, 2025). On August 11, 2026 it issued a final rule making that permanent, effective August 14, 2026 (final rule; FinCEN announcement).
Who still has to report?
Only entities formed under foreign law that have registered to do business in a U.S. state or tribal jurisdiction, and they do not report U.S. persons as beneficial owners or company applicants (FinCEN BOI page). A foreign company that owns U.S. rental property through a registration in a U.S. state should check whether it still files.
| Entity | Files a BOI report? |
|---|---|
| LLC formed in a U.S. state to hold rentals | No |
| U.S. corporation or limited partnership | No |
| Company formed abroad and registered to do business in a U.S. state | Yes, unless another exemption applies, and without reporting U.S. persons |
What about information already filed?
FinCEN said it will delete beneficial ownership information previously reported by U.S. persons, and that U.S. persons with a FinCEN ID do not need to update or correct what they submitted (FinCEN BOI page).
What filings does a rental LLC still have?
- Your state’s annual or biennial report and fee, and a registered agent.
- Federal and state income tax returns: a single-member LLC usually reports on the owner’s Schedule E; a multi-member LLC files a partnership return.
- Forms 1099 for qualifying payments to contractors; see Form 1099 for landlords.
- Some states and cities have their own ownership-disclosure rules for rental property, such as rental registration that names an owner or managing agent.
Frequently asked questions
I filed a BOI report in 2024. Do I need to update it when I add a property?
No. U.S. companies are no longer reporting companies and U.S. persons do not need to update or correct previously filed reports.
Is the Corporate Transparency Act repealed?
No. The statute remains, but FinCEN’s regulations now limit reporting to companies formed under foreign law that register to do business in the United States.
Do I still need an LLC for my rentals?
That is a liability and tax decision, not a BOI question. The final rule does not affect whether an LLC is useful for you.
Sources
- Beneficial Ownership Information Reporting Requirement Revision (final rule, August 14, 2026), Federal Register
- Beneficial Ownership Information Reporting Requirement Revision and Deadline Extension (interim final rule, March 26, 2025), Federal Register
- FinCEN Permanently Ends Beneficial Ownership Reporting Requirements for Millions of Small Business Owners, FinCEN
- Beneficial Ownership Information Reporting, FinCEN
How Seayora helps
Property management accounting: Separate books per entity, so each LLC’s income and expenses are ready for its own return.
This article is general information, not legal advice. Landlord-tenant law varies by state and city and changes often, so check the current rule for your property and talk to an attorney before acting on a dispute.
How we write and check these guides: editorial standards.
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