HOA Beneficial Ownership Information Report: 2026 FinCEN Rule
Quick answer: No. An HOA or condo association formed in the United States does not have to file a beneficial ownership information (BOI) report with FinCEN. FinCEN’s final rule, published in the Federal Register on August 14, 2026 (91 FR 52508) and effective that day, made permanent the March 26, 2025 interim final rule that exempted every entity created in the United States from BOI reporting under the Corporate Transparency Act. Board members do not have to provide their information, and anyone who already holds a FinCEN ID does not have to update it.
If your board filed a BOI report in 2024 or early 2025, or held off waiting for the rules to settle, here is what changed, what is still required, and what to watch for.
What the Corporate Transparency Act required, and why HOAs were caught
The Corporate Transparency Act (CTA) was enacted on January 1, 2021, as part of the Anti-Money Laundering Act of 2020. It added BOI reporting requirements for many corporations, LLCs and similar entities, with exemptions for specified categories of businesses. FinCEN published its original reporting rule on September 30, 2022.
Many associations worried because the main nonprofit exemption covered organizations exempt under section 501© of the tax code. Many HOAs and condo associations are not 501© organizations; they file Form 1120-H or Form 1120 each year instead. That left many self-managed boards unsure whether their nonprofit corporation was a reporting company. Confirm how your own association was treated with your CPA or attorney if you need a record of past filings.
What changed in 2025 and 2026
| Date | What happened | Effect on a U.S. HOA |
|---|---|---|
| March 26, 2025 | FinCEN published an interim final rule redefining reporting company to mean only entities formed under foreign law and registered to do business in a U.S. state or tribal jurisdiction | U.S.-formed entities, including HOAs, exempt from BOI reporting |
| August 11, 2026 | FinCEN issued the final rule and press release | Exemption made permanent; relief expanded for U.S. persons |
| August 14, 2026 | Final rule published (91 FR 52508) and took effect | No BOI report, no updates, no corrections for U.S. companies |
According to FinCEN’s BOI page, under the final rule:
- U.S. companies are exempt from BOI reporting and no longer have to file BOI reports.
- Reporting companies do not report BOI for U.S. person beneficial owners or U.S. person company applicants.
- U.S. persons do not have to provide BOI to reporting companies.
- U.S. persons with a FinCEN ID do not have to update or correct the information they previously submitted.
FinCEN’s August 11, 2026 press release also says it will delete previously reported information of U.S. persons, who are now exempt, from the BOI database. Only certain foreign companies registered to do business in the U.S. still report, and they do not report U.S. persons.
What this means for your board
- Don’t file anything new. A U.S.-formed HOA, condo association or cooperative has no BOI filing, update or correction obligation.
- New board members don’t owe FinCEN anything. Changes in officers or directors no longer trigger an updated report.
- Old filings can stay as they are. You do not need to withdraw or correct a report filed in 2024 or 2025.
- Note it in the minutes. A one-line board record that the association relied on the FinCEN final rule effective August 14, 2026 closes the item for future boards. See our sister site’s guide to HOA board secretary duties for where that note belongs.
Watch for BOI scams
FinCEN warns that scammers have used beneficial ownership reporting to solicit money and personal information. Its BOI page lists these warning signs:
- Letters referencing a Form 4022 or Form 5102. FinCEN has no such forms.
- Letters from a US Business Regulations Dept. No government entity by that name exists.
- Any request for payment. There is no fee to file BOI with FinCEN, and FinCEN does not send letters asking for payment.
- Suspicious links or QR codes, and penalty demands by email or phone.
Board members’ addresses are public in many states’ corporate records, so expect these letters to reach volunteers at home. Forward them to the board and do not pay or respond.
Federal filings an HOA still owes
BOI is off the list, but the federal compliance calendar for a self-managed association is not empty.
| Filing | Who files | When |
|---|---|---|
| BOI report (FinCEN) | Not required for U.S.-formed associations | None |
| Form 1120-H or Form 1120 (IRS) | Every association, every year | 15th day of the 4th month after the tax year ends |
| Form 1099-NEC (IRS) | Associations that paid an unincorporated vendor above the reporting threshold | January 31 |
| Bank account documentation | When you open or change bank accounts | Per your bank’s requirements |
Banks follow their own customer due diligence rules, which are separate from the CTA, so your bank may still ask who controls the association’s accounts when you add signers. Confirm what your bank requires.
Our guides cover the details: Form 1120-H instructions, HOA 1099 requirements and the new $2,000 threshold, FDIC insurance limits for HOA reserves, and the full how to self-manage an HOA playbook.
By state: does any state replace the federal BOI filing?
The FinCEN rule only addresses the federal report. Your state still has its own nonprofit corporation filings, usually an annual or biennial report with the secretary of state listing officers or directors, and some states regulate associations directly. Those requirements vary by state and are unchanged by the FinCEN rule. Check your secretary of state’s site, and for state-specific HOA statutes see Dynamite Management’s state law guides.
Could this change again?
The CTA itself is still a federal statute. The exemption for U.S. companies exists because of FinCEN’s regulations, which rely on the Treasury’s authority to exempt entities or classes of entities. A future rule or an act of Congress could change that, so check FinCEN’s BOI page once a year when you prepare your annual tax return.
HOA Fiscal tracks your tax filing, 1099 vendors and bank accounts in one place for self-managed boards. If you’d rather hand off the financial side, associations can upgrade to Dynamite Management, which prepares Form 1120-H for $175 flat (state return +$100 flat, any state).
This is not legal advice. Confirm the details with FinCEN’s final rule and your attorney or CPA.
Frequently asked questions
Do HOAs have to file a BOI report in 2026?
No. Under FinCEN’s final rule effective August 14, 2026, entities created in the United States, including HOAs and condo associations, are exempt from BOI reporting.
Does our HOA need to update a BOI report we filed in 2024?
No. U.S. companies no longer have reporting obligations, and U.S. persons with a FinCEN ID do not have to update or correct their information. FinCEN has said it will delete U.S. persons’ previously reported information.
Do new board members have to give the association their personal information for FinCEN?
No. Under the final rule, U.S. persons do not have to provide BOI to reporting companies, and U.S. associations are not reporting companies.
We got a letter about a Form 4022 BOI filing fee. Is it real?
No. FinCEN has no Form 4022 or Form 5102 and charges no fee to file. Treat it as a scam.
Who still has to file BOI reports?
Only certain entities formed under foreign law and registered to do business in a U.S. state or tribal jurisdiction, and they do not report U.S. persons.
Keep reading
HOA 1099 Requirements for 2026: The New $2,000 Threshold
Which vendors an HOA must send a Form 1099-NEC, the new $2,000 threshold for 2026 payments, the exceptions, and a year-end routine for treasurers.
Form 1120-H Instructions for HOA Treasurers: How to File Your Association's Tax Return (2026 Tax Year)
Line-by-line Form 1120-H instructions for HOA treasurers: the 60%/90% tests, exempt function income, 30% tax, the April 15 due date and the election.