FinCEN ID: what it is, who needs one, and how to get it in 2026
If you are a foreign national who owns or represents a foreign-formed company registered to do business in a US state, the FinCEN ID may be relevant to your beneficial ownership information reporting obligations.
The regulatory picture shifted in 2025 and 2026. FinCEN permanently ended BOI reporting for US companies and US persons on August 14, 2026. The requirement remains in effect only for foreign reporting companies and their non-US beneficial owners.
This article covers what a FinCEN ID is, who still needs one after the 2026 rule change, how to apply, and how the ID interacts with FBAR, FATCA, and other US compliance obligations.
What is a FinCEN ID? Quick answer
A FinCEN ID is a unique 12-digit number issued by the Financial Crimes Enforcement Network that a beneficial owner or reporting company can use in place of submitting personal identifying information directly on a beneficial ownership information report.
Once you receive your FinCEN identification number, you reference that 12-digit number on every BOI report instead of re-entering sensitive data such as passport numbers, dates of birth, and residential addresses.
The Corporate Transparency Act – the CTA – enacted as part of the Anti-Money Laundering Act of 2020, created this reporting framework. As of August 14, 2026, BOI reporting applies only to foreign-formed entities registered to do business in a US state or tribal jurisdiction. US companies and US persons are permanently exempt.
FinCEN ID vs. EIN: understanding the difference
An EIN identifies your business to the IRS for tax purposes; a FinCEN ID identifies beneficial owners to FinCEN for ownership transparency – they serve entirely different regulatory functions.
An Employer Identification Number – an EIN – is a nine-digit number the IRS assigns to business entities for federal tax filing, payroll, and banking.
A FinCEN ID is a 12-digit number FinCEN assigns for use on BOI reports filed under the Corporate Transparency Act. The two numbers answer to different agencies, cover different obligations, and cannot substitute for each other.
Key differences at a glance:
- Issuing agency: IRS for the EIN vs. FinCEN for the FinCEN ID
- Purpose: Federal tax identification vs. beneficial ownership transparency under the CTA
- Who uses it: Any entity with a US tax obligation vs. beneficial owners and reporting companies filing BOI reports
- Regulatory scope: Internal Revenue Code vs. Bank Secrecy Act / Corporate Transparency Act
Having an EIN does not satisfy BOI reporting, and having a FinCEN ID does not replace the EIN required on tax returns. A reporting company lists both its EIN – or foreign TIN – and the FinCEN IDs of its beneficial owners on the same BOI report.
See our EIN guide for foreign entities for the separate IRS application process.
Who needs a FinCEN ID? Eligibility and use cases
Any individual who qualifies as a beneficial owner of a reporting company may voluntarily apply for a FinCEN ID to streamline future BOI filings. No one is required to get one, but it becomes highly practical in specific situations.
Two categories of applicants are eligible:
- Individual beneficial owners. Under the August 2026 final rule, only non-US-person beneficial owners of foreign reporting companies are reported on BOI filings. US persons are exempt from both the reporting obligation and the requirement to maintain a FinCEN ID.
- Reporting companies. A foreign-formed entity registered to do business in a US state can request a company FinCEN ID when it files its BOI report. That company ID can then be referenced on BOI reports filed by other entities where the company appears as a beneficial owner.
FinCEN ID for expats and foreign nationals: why it matters
For non-US persons who own or control foreign entities registered to do business in the United States, a FinCEN ID is the single most efficient way to protect personal data while meeting Corporate Transparency Act obligations.
US expats who are US citizens or green card holders are classified as US persons under IRC § 7701(a)(30). They are exempt from BOI reporting as of the August 2026 final rule, and FinCEN has stated it will delete their previously submitted FinCEN ID data.
Foreign nationals who are not US persons and who own or control foreign reporting companies registered in the US still have active obligations.
Pain points a FinCEN ID solves for non-US beneficial owners:
- Repeated document submission. Without a FinCEN ID, a non-US beneficial owner submits their passport scan, foreign address, and date of birth on every BOI report for every entity they own
- Data exposure across multiple filings. Each submission creates another copy of sensitive personal data in the FinCEN system
- Cross-border complexity. Foreign nationals often hold identification documents from multiple jurisdictions – a FinCEN ID lets them resolve document selection once
See our guide on forming a US LLC as a non-resident for the broader entity formation and tax filing picture.
How to apply for a FinCEN ID: step-by-step
Applying for a FinCEN ID requires only a government-issued photo ID and basic personal information.
The identifier is issued immediately upon submission – there is no review period or approval queue.
How to get a FinCEN ID through the FinCEN ID portal
The individual application uses a dedicated portal at fincenid.fincen.gov, separate from the BOI e-filing system. Follow these steps:
- Create or log in to a login.gov account. Go to fincenid.fincen.gov and click the Login.gov button. If you do not already have an account, complete the registration steps: an email address and a second authentication method. You’ll provide your identifying document later, directly in the FinCEN ID application.
- Access the FinCEN ID application. After logging in, select “Apply for a FinCEN ID” on the portal dashboard.
- Submit your identifying information. Enter your full legal name, date of birth, current residential address, and the unique identifying number from an acceptable government-issued document – such as a non-expired passport, state ID, or driver’s license – along with the issuing jurisdiction and an image of the document.
- Receive your 12-digit FinCEN identifier. The number is issued immediately upon submission. Save it in a secure location.
Creating a FinCEN ID does not cost anything. FinCEN does not charge an application fee.
How companies obtain a FinCEN ID
Companies do not use the individual portal. A reporting company requests a FinCEN ID by checking a box on its BOI report at boiefiling.fincen.gov. A company can only obtain a FinCEN ID at or after the time it submits an initial report.
Information required for a FinCEN ID application
FinCEN requires exactly four categories of information to issue an individual FinCEN identifier – the same information that would otherwise appear directly on a BOI report.
Your FinCEN ID application requires:
- Full legal name – as it appears on your identifying document
- Date of birth
- Current residential address – foreign nationals without a US address use their foreign residential address; company applicants who form entities in the course of business may use a business address
- Unique identifying number from an acceptable document, plus the issuing jurisdiction and an image of the document
The FinCEN ID requirements come down to document selection. Acceptable documents are a non-expired US passport, state driver’s license, state, local, or tribal ID, or – only if none of these are available – a non-expired foreign passport.
Company FinCEN ID data
For a company FinCEN ID, the entity provides the data fields from its BOI filing:
- Legal name and any trade or DBA names
- Street address of its US principal place of business – or primary US location if no principal place exists
- Foreign jurisdiction of formation and the US state where it registered
- IRS taxpayer identification number – or foreign TIN with issuing jurisdiction if no US TIN exists
FinCEN ID for multiple companies: the key efficiency benefit
A single FinCEN ID can be referenced on an unlimited number of BOI reports, making it the most practical tool for non-US persons who own or control multiple foreign reporting companies registered in the United States.
Based on a common TFX client scenario: A foreign national living in Germany owns three separate foreign-formed entities, each registered to do business in a different US state. Without a FinCEN ID, that individual submits their passport image, foreign residential address, and date of birth three separate times – once on each entity’s BOI report.
With a FinCEN ID, they submit that information once through fincenid.fincen.gov and reference the 12-digit number on all three filings. The efficiency benefit scales with the number of entities.
A company FinCEN identifier works similarly: if one foreign reporting company is itself a beneficial owner of another, the first entity’s FinCEN ID can appear on the second entity’s BOI report – but only when both entities share the exact same individual beneficial owners.
See our guide on constructive ownership rules for how ownership attribution can affect who qualifies as a beneficial owner across related entities.
Privacy benefits of a FinCEN ID
By using a FinCEN ID, a beneficial owner limits the exposure of their personal identifying information to a single submission rather than having it replicated across every BOI report filed by every company they own.
The primary benefits of a FinCEN ID center on data protection. Each time you submit a BOI report without one, your passport number, home address, and date of birth are entered into the FinCEN system as part of that specific filing.
For non-US persons who own multiple reporting companies, this creates redundant copies of sensitive data. A FinCEN ID consolidates that data into one record. When a reporting company references your FinCEN ID, the report contains the 12-digit number instead of your underlying personal details.
This is particularly relevant for non-US entrepreneurs and high-net-worth foreign nationals whose personal data would otherwise appear in filings for each of their US-registered entities.
Updating your FinCEN ID: the 30-day rule
If any information associated with a FinCEN ID changes, the holder must update their FinCEN account within 30 days – but this obligation now applies only to non-US persons.
FinCEN’s August 2026 final rule permanently exempted US persons from the requirement to update or correct FinCEN ID information. US persons who previously obtained a FinCEN ID do not need to take any action.
For non-US persons, the 30-day update requirement remains in effect. Events that trigger an update:
- New government-issued identification document – a new passport number, renewed ID, or replacement document
- Change of residential address
- Legal name change
- Expiration or replacement of the identification document used in the original application
Non-US individuals update through the same fincenid.fincen.gov portal used for the original application. The FinCEN ID number itself does not change – only the underlying data is updated.
Reporting companies update by filing a corrected BOI report through boiefiling.fincen.gov, using the same 30-day deadline.
FinCEN ID vs. BOI report: what is the difference?
A BOI report is the required disclosure document; a FinCEN ID is an optional shortcut that replaces the personal data fields within that document – you still need to file the BOI report regardless of whether you have a FinCEN ID.
The two are not alternatives. One is the filing, the other is a tool that makes the filing easier.
Under 31 CFR 1010.380, a reporting company may report a beneficial owner’s FinCEN identifier in place of that individual’s name, date of birth, address, and identifying document details.
The company still files the BOI report itself, including its own entity information and any beneficial owners who do not hold a FinCEN ID.
Corporate Transparency Act and the FinCEN ID: the legal framework
The Corporate Transparency Act is the law that made FinCEN IDs relevant – it requires certain entities to disclose their beneficial owners to FinCEN, and the FinCEN ID is the mechanism that makes repeat disclosures more efficient.
CTA timeline
The CTA was enacted on January 1, 2021, as part of the Anti-Money Laundering Act of 2020. It added 31 USC § 5336 to the Bank Secrecy Act, directing FinCEN to collect beneficial ownership data and authorizing the issuance of FinCEN identifiers.
FinCEN’s implementing rule took effect January 1, 2024. The CTA faced legal challenges, including a nationwide injunction in late 2024 and a Supreme Court stay in January 2025.
Current enforcement status
In March 2025, Treasury announced it would no longer enforce BOI reporting against US companies or US persons. FinCEN issued an interim final rule on March 26, 2025, narrowing the definition of “reporting company” to foreign-formed entities only.
On August 11, 2026, FinCEN finalized these changes permanently. On October 5, 2026, the Supreme Court declined certiorari in two pending CTA cases, leaving the statute standing.
The CTA’s penalty provisions remain in force for foreign reporting companies and non-US persons.
See our CTA enforcement timeline for the full history of court orders and regulatory changes.
FinCEN BSA ID: Is it the same as a FinCEN ID?
They are entirely different numbers with different purposes.
The Bank Secrecy Act is the overarching anti-money-laundering law under which FinCEN operates. The BSA E-Filing System processes filings such as Suspicious Activity Reports, Currency Transaction Reports, and FBARs.
Each filed BSA report receives a unique 14-digit BSA Identifier – typically beginning with “31” – that confirms the filing was received. This is a per-report tracking number. It identifies a specific filing, not a person or institution. An FBAR filer, for example, receives a BSA Identifier as a confirmation number after submitting FinCEN Form 114.
The 12-digit FinCEN ID created under the CTA is entirely separate. It is assigned to an individual or reporting company, used across multiple BOI reports, and obtained through a different application process. For non-US owners of foreign-formed companies registered in the US, the relevant identifier is the BOI-context FinCEN ID.
FinCEN ID deadlines and current enforcement status
Because FinCEN ID applications are voluntary and tied to BOI reporting deadlines that have been subject to legal challenges, anyone with an active filing obligation should monitor official FinCEN announcements before assuming any specific deadline applies.
Under the current rule, the BOI reporting deadlines that remain in effect apply only to foreign reporting companies:
- Registered before March 26, 2025: Initial BOI report was due by April 25, 2025
- Registered on or after March 26, 2025: 30 calendar days from the date the entity receives notice that its registration is effective
There is no standalone deadline for obtaining a FinCEN ID. An individual can apply at any time. Applying before a BOI report is due means the FinCEN identifier is ready to use when the filing window opens.
US companies and US persons face no BOI deadlines. FinCEN permanently removed their obligations effective August 14, 2026.
Penalties for inaccurate or outdated FinCEN ID information
Because a FinCEN ID substitutes for personal data in a BOI report, any inaccuracy in the underlying FinCEN ID information is treated as an inaccuracy in the BOI report itself – with the same potential penalties.
There is no separate penalty specifically for FinCEN ID errors. Willfully providing false or fraudulent beneficial ownership information – or willfully failing to report complete or updated information – triggers penalties under the same CTA enforcement provisions that apply to any BOI reporting violation.
This is true whether the information was submitted directly on a BOI report or through a FinCEN ID application.
Penalty structure under current law:
- Civil penalties: Up to $606 per day that a violation continues, for assessments on or after January 17, 2025. The penalty requires willfulness – FinCEN has stated that enforcement will not target inadvertent mistakes.
- Criminal penalties: A fine of up to $10,000, imprisonment of up to two years, or both, for willful violations.
These penalties now apply only to foreign reporting companies and non-US persons with active BOI or FinCEN ID obligations. US persons and domestic entities face no penalty exposure.
FinCEN ID for LLC owners: what you need to know
Every individual who qualifies as a beneficial owner of a reporting company – whether through 25% or more ownership interest or through substantial control – is eligible to obtain a FinCEN ID and use it on that company’s BOI report.
Under the CTA, a beneficial owner is anyone who directly or indirectly exercises substantial control over a reporting company, or who owns or controls at least 25% of its ownership interests.
“Substantial control” is read broadly. It can include senior officers, individuals who direct major decisions, or anyone who exercises significant influence through contracts, family relationships, or trusts.
Do US-formed LLCs still need to file?
For LLC owners specifically, the key question after the August 2026 rule change is whether the LLC is a reporting company at all. A US-formed LLC – including a foreign-owned single-member LLC – is now exempt from BOI reporting under the domestic entity exemption.
Only LLCs formed under the law of a foreign country and registered to do business in a US state are still reporting companies.
See our foreign company tax reporting guide for Form 5471, Form 8865, and Form 5472 requirements that may still apply to US-formed LLCs.
FinCEN ID lookup: Can you search for an existing FinCEN ID?
There is no public FinCEN ID lookup database – your FinCEN ID is a private identifier accessible only through your FinCEN account, and it is shared only with FinCEN when referenced in a BOI report.
FinCEN does not provide a search tool that allows third parties to look up a FinCEN ID by name, company, or any other identifier. The number is visible only to the holder – through their account at fincenid.fincen.gov – and to FinCEN when it processes a BOI report that references the ID.
Authorized government agencies with access to the BOI database can see the underlying information, but the database is not publicly accessible.
If you have lost your FinCEN ID, log back into your FinCEN account through login.gov to retrieve it. The number does not change over time.
FBAR, FATCA, and FinCEN ID: how they relate
FBAR, FATCA, and FinCEN ID requirements are three separate compliance obligations that can all apply simultaneously to a person who holds a foreign bank account and owns a reporting company registered in the United States – none of them substitutes for the others.
All three fall under the Treasury Department or FinCEN umbrella, but they serve different purposes:
- FBAR – FinCEN Form 114: Reports foreign financial accounts when the aggregate value exceeds $10,000 at any point during the year. Filed through the BSA E-Filing System. Applies to US persons only.
- FATCA – Form 8938: Reports specified foreign financial assets above thresholds that vary by filing status and residence. Filed with the income tax return. Applies to specified individuals and specified domestic entities.
- FinCEN ID: An optional 12-digit identifier used on BOI reports filed under the Corporate Transparency Act. Applies to beneficial owners and reporting companies involved in BOI filings.
FBAR and FATCA are account- and asset-reporting requirements. The FinCEN ID is an entity-ownership reporting tool. A non-US person who owns both a foreign bank account and a foreign-formed US-registered company may need to deal with all three.
Frequently asked questions
A FinCEN ID – also called a FinCEN identification number – is a unique 12-digit number issued by FinCEN. Beneficial owners and reporting companies use it on BOI reports in place of personal identifying information.
No – obtaining one is voluntary. It is useful if you are a non-US person who is a beneficial owner of a foreign reporting company registered in the US. US persons and US companies are exempt from BOI reporting as of August 14, 2026.
You can get a FinCEN ID immediately – the identifier is issued upon submission through fincenid.fincen.gov.
No. A FinCEN ID does not expire and cannot be replaced with a different number. Non-US persons must update the underlying information within 30 days of any change.
Yes. Foreign nationals who are beneficial owners of foreign reporting companies registered in the US may apply using a foreign passport and foreign residential address – provided they do not hold a non-expired US passport, state ID, or driver’s license.
An EIN is a nine-digit IRS tax identifier used for federal tax filing. A FinCEN identifier is a 12-digit FinCEN-issued number used only for BOI reporting under the Corporate Transparency Act.
Yes. A single FinCEN ID number can be referenced on BOI reports for any number of reporting companies where you are disclosed as a beneficial owner.
For non-US persons, the associated BOI reports may be considered inaccurate. Willful failure to update within 30 days can trigger civil penalties of up to $606 per day and criminal penalties of up to $10,000 and two years’ imprisonment.
No. US persons – including US citizens and green card holders – are permanently exempt from BOI reporting and FinCEN ID obligations. FinCEN has stated it will delete previously submitted US-person FinCEN ID data.
Related articles
Learn who must file an FBAR in 2026, which foreign accounts to report, how the $10,000 threshold works, and the April and October 2026 deadlines.
Read more
Learn FBAR Form 114 filing requirements, the $10,000 threshold, 2026 deadline, extensions, account reporting rules, and how to file with FinCEN.
Read more
Learn how to fix FBAR mistakes with the right correction path, penalty guidance, and filing steps for amended FBARs, delinquent submissions, streamlined procedures, and VDP.
Read more
Learn how to get an ITIN for nonresidents in 2026. Step-by-step guide covering Form W-7, required documents, certifying agents, and processing times.
Read more
Need an EIN for a foreign entity? Learn who needs one, how to file Form SS-4, 2026 processing times, and the US forms due next.
Read more
Learn how non-US residents can form a US LLC, choose a state, open a bank account, and understand tax filing obligations with practical step-by-step guidance.
Read more
Understand FBAR signature authority in 2026: definition, exceptions, examples, and how it differs from financial interest. Stay compliant with FinCEN 114 reporting.
Read more
Learn FBAR joint filing rules for married couples, including Form 114a, joint-account reporting, separate accounts, deadlines, and when two FBARs are required.
Read more
Do Wise and Revolut accounts need FBAR reporting? Learn how to report Wise on FBAR, find the correct address, deadlines, and whether these fintechs report to the IRS.
Read more
