Yes. The company must file a BOI report if it meets the definition of a reporting company and fails to meet the criteria for the large operating company exemption (or any other exemption). If the company initially files a BOI report and later becomes exempt as a large operating company, it should submit a "newly exempt entity" BOI report to FinCEN, indicating its new found exemption status. Should the company cease to meet the criteria for the large operating company exemption or any other exemption in the future, it must file an updated BOI report with FinCEN within 30 calendar days of the change.
To qualify for the large operating company exemption, an entity must meet the following requirements: it must employ more than 20 full-time workers in the United States, have submitted a federal income tax or information return in the United States during the previous year, demonstrating over $5,000,000 in gross receipts or sales, and maintain a physical office presence in the United States.