The Corporate Transparency Act exempts 23 categories of entities from BOI reporting. The March 2025 interim final rule added a 24th: all domestic reporting companies. Here is every exemption explained.
By Alif Al Razi, Tax & Compliance Lead, Anonymousllc.co · Last updated 2026-05-21
Regulatory disclosure: Exemption status may change if FinCEN issues a revised final rule. Track current status at /boi/status-tracker/.
On March 21, 2025, FinCEN published an interim final rule (90 FR 13688) exempting all domestic reporting companies from BOI filing requirements. A domestic reporting company is any entity formed by filing a document with a US secretary of state or similar office. This covers every LLC, corporation, LP, and similar entity formed in any US state.
For anonymous LLC holders, this is the exemption that matters. Small private LLCs in Wyoming, New Mexico, Delaware, and Nevada do not qualify for any of the 23 original exemptions below — they lack the employee count, revenue, regulatory registration, or tax-exempt status required. The domestic exemption covers them regardless.
Under 31 CFR 1010.380(c)(2), the following entity types were exempt from BOI reporting even before the March 2025 rule. These exemptions still apply to foreign reporting companies — a foreign entity that falls into one of these categories does not need to file BOI reports even though it is a foreign reporting company.
Entity that issues securities registered under Section 12 of the Securities Exchange Act of 1934 or is required to file supplementary and periodic information under Section 15(d).
Federal, state, local, Indian tribal, or foreign government entity exercising governmental authority.
Bank as defined in 31 USC 5312(a)(2) or 12 USC 1813(a)(1), including FDIC-insured depository institutions.
Federal or state credit union as defined in the Federal Credit Union Act.
Bank holding company or savings and loan holding company as defined in the Bank Holding Company Act.
Money transmitting business registered with FinCEN under 31 CFR 1010.100(ff).
Entity registered as a broker or dealer under Section 15 of the Securities Exchange Act of 1934.
Exchange or clearing agency registered under Section 6 or 17A of the Securities Exchange Act.
Any other entity registered with the SEC under the Securities Exchange Act of 1934.
Registered under the Investment Company Act of 1940 or the Investment Advisers Act of 1940.
Investment adviser that has filed notice with the SEC as a venture capital fund adviser under the Investment Advisers Act.
Insurance company as defined in Section 2 of the Investment Company Act of 1940.
Entity authorized by a state and subject to supervision by the state insurance commissioner or similar official.
Entity registered with the CFTC under the Commodity Exchange Act.
Public accounting firm registered under Section 102 of the Sarbanes-Oxley Act.
Regulated public utility providing telecommunications, electrical power, natural gas, or water and sewer services.
Designated financial market utility under Title VIII of the Dodd-Frank Act.
Entity operated or advised by a bank, insurance company, registered investment company, or registered investment adviser as a pooled investment vehicle.
Entity described in Section 501(c), 527, or 4947(a)(2) of the Internal Revenue Code that has received a determination letter or is otherwise exempt.
Entity operating exclusively to provide financial assistance to or hold governance rights in a tax-exempt entity.
Entity with more than 20 full-time employees in the United States, more than $5 million in gross receipts or sales on the prior year tax return, and an operating presence at a physical office in the United States.
Entity whose ownership interests are controlled or wholly owned, directly or indirectly, by one or more entities in exemption categories 1-17, 19, or 21.
Entity that was in existence on or before January 1, 2020, is not engaged in active business, is not owned by a foreign person, has not changed ownership in the preceding 12 months, has not sent or received more than $1,000, and holds no assets.
In almost all cases, none of the 23 original exemptions apply to anonymous LLC holders. The typical anonymous LLC is a small, privately held entity with fewer than 20 employees, under $5 million in revenue, no SEC or CFTC registration, no banking charter, and no tax-exempt status. The large operating company exemption (#21) is the closest candidate, but most anonymous LLCs do not meet all three requirements simultaneously.
The inactive entity exemption (#23) applies only to entities formed before January 1, 2020 that meet all six conditions — no active business, no foreign ownership, no ownership changes, under $1,000 in transactions, and no assets. Most operating LLCs fail at least one condition.
The domestic exemption from the March 2025 interim final rule is what makes anonymous LLC holders exempt today. If that rule is revised or withdrawn, anonymous LLC holders would need to file unless they qualify for one of the 23 above.
Anonymousllc.co files BOI reports for foreign reporting companies at a flat $150. We will assess your exemption status for free before you pay anything.
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