Connecticut associations are permanently out of beneficial ownership reporting
Connecticut associations are permanently out of beneficial ownership reporting
2026-09-09 · Connecticut · Compliance
A Connecticut nonstock corporation that operates a condominium or homeowners association has no beneficial ownership reporting obligation, and its volunteer directors have none either. A final rule announced August 11, 2026 and effective August 14 permanently ends the requirement for entities created in the United States.1
That closes a question that produced two years of conflicting advice to Connecticut boards.
How it got here
The Corporate Transparency Act required “reporting companies” to file beneficial ownership information with the Financial Crimes Enforcement Network. Community associations are typically incorporated — in Connecticut, usually as nonstock corporations — and nothing in the original framework clearly exempted them. Boards across the country were told they might have to report their directors’ personal details, with penalties for failure.
March 2025: FinCEN issued an interim final rule stating that “all entities created in the United States — including those previously known as ‘domestic reporting companies’ — and their beneficial owners will be exempt from the requirement to report BOI to FinCEN.”2
August 2026: the final rule made it permanent, and FinCEN said it will delete information previously submitted by filers now exempt.1
What this means for a Connecticut board
Nothing to file. Nothing to update when directors change. Nothing to correct. And for associations that filed during the window when the obligation appeared to apply, the submitted information is to be deleted.
The distinction that matters is between the interim posture and the current one. Between March 2025 and August 2026 the exemption existed but rested on an interim rule issued during ongoing litigation, which is why cautious advice often stopped short of telling boards the question was closed. It is now a final rule.
The Connecticut filing that does still exist
Removing a federal obligation makes it worth restating the state one, because that is the filing Connecticut associations actually miss.
A Connecticut nonstock corporation must file an annual report with the Secretary of the State. The fee is $50, due by the last day of the anniversary month of incorporation.
The consequence of missing it in Connecticut is unusually sharp: the state can dissolve a delinquent nonstock corporation, and reinstatement requires payment for each delinquent year plus a reinstatement fee.
For a volunteer-run association this is a live exposure, and it has nothing to do with FinCEN. A dissolved association is one whose authority to act — to record and enforce liens, to contract, to sue — becomes contestable at exactly the moment it matters.
Two facts decide this: the anniversary month and who is responsible for the filing. Where a managing agent handles it, an explicit management-contract term settles it; assumption does not.
Where association records obligations actually come from
With the federal reporting question resolved, the operative disclosure duties on a Connecticut association are entirely state ones.
Section 47-260 governs records. An association must retain the list at subsection (a) — including the names of unit owners and votes each may cast, and a list of current executive board members and officers — and must withhold the categories at subsection (c).
From October 1, 2026, those records become auditable on petition. Public Act 26-31 lets owners holding twenty per cent of the votes petition the Superior Court to order an independent third-party audit of the association's financial records, subject to a forensic accountant's signed opinion.
So the direction of travel in Connecticut is the opposite of the federal one: less federal reporting of who the directors are, more state-law scrutiny available to owners of what the association did with the money.
A note on advice that is now out of date
Material published to Connecticut boards in 2024 and early 2025 about Corporate Transparency Act compliance — deadlines, director information collection, penalty exposure — is superseded. Associations that adopted a policy for collecting directors' personal identifying information solely to meet the reporting requirement should revisit it, because holding that data now serves no compliance purpose while carrying ordinary data-handling risk.
What to watch next
The rule as made applies to entities created in the United States. Its stability is a matter of federal policy rather than anything Connecticut controls, and a final rule can be revisited by a future rulemaking.
For a Connecticut board the practical answer is that there is nothing to do, no deadline to diarise, and one state filing — the annual report — that deserves the attention the federal question was absorbing.
Related Connecticut HOA Topics
- FinCEN Permanently Ends Beneficial Ownership Reporting Requirements for Millions of Small Business Owners, U.S. Department of the Treasury (August 11, 2026; effective August 14, 2026) ↩
- FinCEN Removes Beneficial Ownership Reporting Requirements for U.S. Companies and U.S. Persons, interim final rule (March 21, 2025) ↩
- Public Act No. 26-31, § 1 — court-ordered audit of association financial records, effective October 1, 2026 ↩
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