Beneficial Owner Information
You will now be required to file the information with the federal government directly. The purpose of collecting BOI is to promote transparency in the ownership of businesses for our law enforcement community.
FinCEN began accepting beneficial ownership information reports from reporting companies1 that are not exempt2 on January 1, 2024, the effective date of the reporting requirement.
Initial Reports
If your company existed before January 1, 2024, it must file its initial beneficial ownership information report by January 1, 2025.
If your company was created or registered on or after January 1, 2024, and before January 1, 2025, then it must file its initial beneficial ownership information report within 90 calendar days after receiving actual or public notice that its creation or registration is effective. Specifically, this 90-calendar day deadline runs from the time the company receives actual notice that its creation or registration is effective, or after a secretary of state or similar office first provides public notice of its creation or registration, whichever is earlier.
If your company was created or registered on or after January 1, 2025, it must file its initial beneficial ownership information report within 30 calendar days after receiving actual or public notice that its creation or registration is effective.
Chapter 5.1 “When should my company file its initial BOI report?” of FinCEN’s Small Entity Compliance Guide has additional information about the reporting timelines.
Updated Reports
If there is any change to the required information about your company or its beneficial owners in a beneficial ownership information report that your company filed, your company must file an updated report no later than 30 days after the date of the change.
A reporting company is not required to file an updated report for any changes to previously reported information about a company applicant.
Chapter 6.1, “What should I do if previously reported information changes?” of FinCEN’s Small Entity Compliance Guide provides additional information.
Corrected Reports
If a beneficial ownership information report is inaccurate, your company must correct it no later than 30 days after the date your company became aware of the inaccuracy or had reason to know of it. This includes any inaccuracy in the required information provided about your company, its beneficial owners, or its company applicants.
Chapter 6.2, “What should I do if I learn of an inaccuracy in a report?” of FinCEN’s Small Entity Compliance Guide includes additional information about correcting inaccurate beneficial ownership information reports filed with FinCEN.
1 There are two types of reporting companies: domestic and foreign. A domestic reporting company is any entity that is a corporation, a limited liability company (LLC), or created by the fling of a document with a secretary of state or any similar office under the law of a U.S. state or Indian inbe. A foreign reporting company is any entity mat is a corporation, LIt, or oiner entity that is tormed under the law of a foreign country and registered to do business in any U.S. state or inbal jurisdiction by the fling ot a document with a secretary ot state or any similar office under the law of a U.S. state or Indian tribe.
2 There are 23 categories of entities that are exempt from the definition of reporting company. Please review FinCEN’s final beneficial ownership information reporting rule, as well as FinCEN’s reference materials published on www.fincen.gov/boi, for more details.