Latest BOI Update: FinCEN Plans to Wipe Small Business Data from the Playbook

As of late September 2025, the Financial Crimes Enforcement Network (FinCEN) announced plans to erase beneficial ownership information (BOI) previously submitted by U.S. small businesses. This comes after earlier changes this year that exempted many domestic businesses from ongoing BOI reporting requirements under the Corporate Transparency Act (CTA). 

Here’s what you need to know for your business to stay ahead of the game.  

What’s The Same 

Prior Exemptions Still in Place 

 The March 2025 ruling, exempting many U.S small businesses from BOI reporting under the CTA is still in effect.  

What’s New 

Removing Old Data from the Field  

FinCEN intends to clear beneficial ownership records already submitted by domestic businesses. For owners concerned about privacy or the security of sensitive information, this could be a major move. 

What Happens Next  

Final Rule Expected by Year-End  

FinCEN plans to issue a final rule by the end of 2025. This rule should: 

• Officially exempt small businesses from future BOI reporting requirements  

• Outline how and when existing BOI data will be cleared off the books 

What’s Still Uncertain 

Even with these updates, some questions remain:   

• Which data will be erased, and which might be held for law enforcement or regulatory purposes 

• The timeframe and process for secure clearance of submitted data 

• Any exceptions or carve-outs for specific businesses or situations 

• How FinCEN will verify that the data has been wiped 

What You Should Do Now 

Keep Your Finger on the Pulse 

Watch for updates from FinCEN and check the Federal Register for the final rule. That’s where the official playbook should land.  

Maintain Your Records 

If you filed BOI in the past, list what you provided—names, addresses, ownership structure. Knowing what’s out there can ensure clarity and preparedness if questions arise during the removal process. 

Check Compliance  

Even with the exemption, other laws or contracts may still require some disclosures or record-keeping. Double-check to avoid surprises.  

Prepare for Changes 

Things could move fast once the final rule is out. Make sure your business is ready: informed, documented, and nimble. We’ll continue to monitor and provide updates as they become available. 

Questions?  

Have questions about how these changes impact your business? Contact us.