Dental practices and other businesses in the U.S. that employ fewer than 20 employees or produce less than $5 million in annual gross receipts have gained permanent exemption from the requirement to report beneficial ownership information to the U.S. Department of Treasury’s Financial Crimes Enforcement Network under the Corporate Transparency Act.
FinCEN on Aug. 11 issued the final rule, effectively ending more than 18 months of enforcement uncertainty for the qualifying small businesses.
Under FinCEN’s original reporting rule, businesses that existed prior to 2024 had until Jan. 1, 2025, to submit a BOI report, while businesses that formed in 2024 or subsequent years had 90 days from business creation or registration to submit a report. But enforcement of the reporting requirement met multiple legal challenges before the compliance deadline, and reporting was never more than voluntary for qualifying businesses.
CDA initially encouraged members to voluntarily file their BOI to achieve compliance and avoid a short-notice filing deadline pending resolution of challenges in court. FinCEN then issued an interim final rule in March 2025 that removed the reporting requirement for small businesses. FinCEN’s final rule issued last week makes that exemption permanent.
The Treasury Department’s August news release states that in addition to adopting the exemptions, the final rule “will delete information about any individuals … that FinCEN reasonably believes is a U.S. person.” Additionally, the release confirms that foreign entities that are reporting companies will still be required to report BOI for foreign individuals.
The purpose of the Corporate Transparency Act, enacted with bipartisan support in 2021, is to curb illicit finance, such as money laundering, drug trafficking and corruption. FinCEN has more information on the final rule, including Q-and-A.