Project 2025 Tracker / What’s done, what’s next

22. Department of the Treasury · Major · Needs Congress

Repeal the Corporate Transparency Act

Partially done

707 22. Department of the Treasury

“Congress should repeal the Corporate Transparency Act, and FinCEN should withdraw its poorly written and overbroad beneficial ownership reporting rule.”

What has happened

  1. Partially done

    FinCEN's final rule made the rollback permanent, exempted U.S. persons holding FinCEN IDs from updating their information, dropped the company-applicant requirement for foreign companies, and committed FinCEN to deleting beneficial ownership information it believes belongs to U.S. persons. Foreign reporting companies must still report foreign beneficial owners, and Congress has not repealed the Corporate Transparency Act — the statute remains in force.

  2. Partially done

    FinCEN's interim final rule (effective on publication) narrowed the beneficial ownership reporting requirement to entities previously defined as foreign reporting companies and exempted all domestic reporting companies. Half the ask — FinCEN withdrawing its rule — was substantially delivered; the Corporate Transparency Act itself was untouched.

  3. Attempted

    Treasury announced it would not enforce any penalty or fine under the Corporate Transparency Act's beneficial ownership reporting rule against U.S. citizens or domestic reporting companies, and that it would propose narrowing the rule to foreign reporting companies only. An enforcement policy, not yet a rule change.

Research log

What was searched, and what didn’t count as evidence

Research notes

  • The Recommendation has two objects. FinCEN’s half is close to complete for U.S. companies; the statutory half is untouched, which is why the Status stops at partial.
  • Repeal bills: jq over bills.ndjson for Corporate Transparency|beneficial ownership returns only the FinCEN–SBA Coordination on Beneficial Ownership Registration Act (H.R. 3829 / S. 1995, both in committee) and S. 4419 (2026-04-28), “to require only foreign entities to report beneficial ownership information” — which would codify the rule change rather than repeal the Act, and is itself still in committee. None is Evidence.
  • Litigation over the Corporate Transparency Act (the Texas Top Cop Shop and NSBU v. Yellen lines) was not run down: the interim and final rules moot it for U.S. companies and no allowlisted opinion was needed for the Status.
Action
repeal
Object
Corporate Transparency Act
ID
1991