Beneficial Ownership and Registers by Country: FinCEN BOI Status, Canada's ISC Register and India's SBO Rules

Beneficial ownership registers by country now diverge sharply. As of October 2026, the United States has removed beneficial ownership reporting for U.S. companies, Canada keeps a private register and, for federal corporations, a federal filing, and India requires companies to collect and report significant beneficial owner (SBO) declarations. For a family that owns an Illinois LLC, a Canadian corporation and an Indian company, each system asks a different question, at a different ownership threshold, of a different registry.

What is the status of beneficial ownership reporting in the United States?

FinCEN's page, updated August 11, 2026, says that FinCEN has finalized its BOI reporting rule. Under the final rule, U.S. companies are exempt and no longer required 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 need not provide BOI to companies; and U.S. persons with a FinCEN ID need not update it. FinCEN also said it will delete previously reported information about U.S. persons from the database. Only foreign entities that register to do business in a U.S. state or tribal jurisdiction remain reporting companies, and they report foreign individuals only. FinCEN lists as outdated any guidance saying that U.S. companies or their beneficial owners must report, that BOI must be reported for U.S. persons, or that U.S. persons must update FinCEN ID information. Read our beneficial ownership reporting status update for the timeline.

Two things stay in place. First, the customer due diligence rule still requires U.S. banks and certain other financial institutions to identify and verify the individuals who own 25% or more of a legal entity customer and an individual who controls it; FinCEN issued 2026 exceptive relief from repeating that at each account opening. Second, state entity records remain public: an Illinois annual report lists managers or officers. See foreign-owned LLC U.S. tax and reporting and foreign qualification in Illinois.

How does Canada's ISC register work?

Since June 2019, most corporations under the Canada Business Corporations Act have been required to keep a register of individuals with significant control (ISCs). An ISC owns, controls or directs 25% or more of voting shares or of the fair market value of all shares, individually, jointly or in concert, or has control in fact. The register lists legal name, date of birth, countries of citizenship and tax residence, residential address, the dates the person became and ceased to be an ISC, and a description of the control.

• Updates: at least once a year and within 15 days of becoming aware of a change; take reasonable steps, including an annual request for information to ISCs and shareholders.
• Federal filing: since January 22, 2024, CBCA corporations file ISC information with Corporations Canada annually with the annual return and within 15 days of a change; some of it is public.
• Exclusions: reporting issuers, certain listed public corporations, Crown corporations and their wholly-owned subsidiaries.
• Provinces: Ontario corporations have had to keep beneficial ownership information at their registered or head office since January 1, 2023, review it at least annually and give it to law enforcement and regulators on request. British Columbia private companies have had to keep a transparency register since October 1, 2020 and update it within 30 days of new information; the public cannot see it.

For the registry side see Canadian corporate annual returns and registers.

How do India's significant beneficial owner rules work?

Section 90 of the Companies Act, 2013 requires every individual who, alone or with others or through a trust, including persons resident outside India, holds beneficial interest of at least 25% (or such other percentage as is prescribed) in a company's shares, or has the right to exercise or actually exercises significant influence or control, to declare it to the company. The Companies (Significant Beneficial Owners) Rules, 2018 set the prescribed threshold at 10% of shares or of capital or profit entitlement for companies, partnerships and trusts in the chain. As published, the rules require:

1. Declaration (Form BEN-1) by the significant beneficial owner to the company within 30 days of acquiring the interest or of a change.
2. Return (Form BEN-2) by the company to the Registrar within 30 days of receiving the declaration.
3. Register kept by the company, open to inspection by members.
4. Active identification: the company must take steps to identify its significant beneficial owners and can give notice to anyone it believes to be one, who must respond within 30 days.
5. Enforcement: if information is not given, the company can apply to the Tribunal to restrict transfer and suspend rights attached to the shares.

MCA's LLP e-filing menu also lists an LLP BEN-2 return, so LLPs have comparable reporting. Rules have been amended since 2018, so your Indian Chartered Accountant confirms current forms and timing. See India private limited company compliance.

How do beneficial ownership registers by country compare?

What should owners with entities in all three countries do?

1. Draw one ownership chart showing every individual down to the ultimate owner in each entity.
2. Test each person against 25% (Canada, banks) and 10% (India), plus control in fact.
3. Update registers when ownership changes, and calendar the 15-day and 30-day windows.
4. Keep an Illinois record of managers and officers current in the annual report.
5. Tell your bank when owners change; the bank applies its own due diligence.

Worked example

Meena (Aurora) and her brother Vikram (Calgary) own 60% and 40% of Maple Imaging Inc., a federal Canadian corporation, which owns 100% of Rao Imaging Pvt Ltd in India and an Illinois LLC in Aurora. Canada: both are ISCs; the register records them and they are filed with the annual return. India: the Pvt Ltd identifies both as indirect significant beneficial owners above 10% and receives BEN-1 declarations. United States: the Illinois LLC does not file with FinCEN under the August 2026 rule, but its bank will still ask for owners of 25% or more and a control person. Meena and Vikram agree to review all three registers every March.

Mistakes to avoid

• Continuing to file or pay for a FinCEN BOI report for a U.S. company on the strength of an old reminder.
• Assuming Canada's 25% test is the Indian test; India's rules use 10%.
• Forgetting that India's SBO definition expressly includes persons resident outside India and trusts.
• Letting a register go stale when a share transfer happens.
• Keeping a nominee-style arrangement undocumented.

How we can help

We are a CPA firm in the Aurora area. We handle the U.S. side of ownership reporting and bank onboarding, including Illinois entity records, and we coordinate with your Canadian CPA or lawyer and your Indian Chartered Accountant who prepare the Canadian and Indian filings. We do not give legal advice on ownership structures. See business formation and registrations and cross-border tax services.

Frequently asked questions

General information only. It is not tax, legal, accounting or immigration advice for your situation, and rules change; confirm the current rules with the official source or a licensed professional in the relevant country.