BOI Reporting Is Basically Dead — Now Federal Agencies Can’t Even Access What’s Left
A new Government Accountability Office report confirms what small business owners tracking the Corporate Transparency Act have suspected for months: the beneficial ownership information (BOI) reporting regime the Treasury Department built to fight shell-company money laundering has been quietly hollowed out, and now even the federal agencies it was designed to serve are struggling to use it.
The Financial Crimes Enforcement Network (FinCEN) rolled out a pilot program in early 2024 giving six federal law enforcement agencies direct access to its beneficial ownership database. According to the GAO, agency searches of that system dropped sharply starting in October 2024 and stayed low all the way through March 2026. FinCEN paused new access requests entirely in December 2024 because of ongoing lawsuits, resumed processing in spring 2025, and had opened access to 22 federal agencies by August 2025 — only to largely pause the program again in December 2025 while it finalizes new rules. Three agencies have since dropped out of the pilot altogether.
The bigger driver, per GAO, is Treasury’s March 2025 interim final rule, which FinCEN itself says “exempted about 99% of entities previously required to report their information.” With the reporting population gutted, there’s simply far less ownership data in the system for agencies to query in the first place.
Why it matters
The Corporate Transparency Act was sold as a tool to unmask anonymous shell companies used for money laundering, fraud, and sanctions evasion. Two years in, the law has been through court injunctions, a near-total exemption for U.S. companies, and now a documented decline in the very federal agency usage that justified building the database. The GAO says Treasury is still working on data-protection policies and that it will keep monitoring FinCEN’s efforts to safeguard and share the information — signaling this saga isn’t fully resolved, just stalled.
What this means for small business owners
If your business already filed a BOI report, or decided not to after the domestic-entity exemption, this doesn’t change your obligations today — the March 2025 rule exempting U.S. companies and persons is still what governs. But it does mean the enforcement infrastructure behind BOI is in worse shape than the rule’s on-paper existence suggests, which is exactly why groups like NFIB have been pushing Congress to permanently repeal the reporting requirement rather than leave it in this half-alive state. For owners still fielding questions from lenders, insurers, or foreign-entity partners about BOI compliance, the honest answer right now is: the rule technically exists, but the system behind it is barely operating. Keep any exemption documentation on file regardless — a change in administration or a court ruling could reactivate reporting duties with little notice.
“About 99% of entities previously required to report their information” were exempted under Treasury’s March 2025 rule — GAO report on FinCEN’s beneficial ownership program.
The bottom line
BOI reporting hasn’t been repealed, but the GAO’s findings show it’s operating in name only for most federal agencies. Small business owners should treat the current exemption as fragile rather than final — file away any documentation and watch for the permanent-repeal push in Congress rather than assuming the issue is closed.
