Based on FinCEN's 3-21-25 interim final ruling, U.S. Companies (entities created in the US) and U.S. Persons are EXEMPT from BOIR filing requirements. "Reporting companies" who must still file are now only foreign companies that have registered to do business in the U.S. These foreign entities, however, will not be required to report any U.S. persons as beneficial owners. (Updated as of 3-21-2025)
Please visit fincen.gov/boi for the most updated information.
New Filing Requirement for Businesses:
FinCEN
BENEFICIAL OWNERSHIP REPORTS (BOIR)
Under the new 2024 Corporate Transparency Act filing requirements, each* corporation, LLC, or other similar entity (but not a sole proprietorship/DBA) must file a report with the government disclosing its “beneficial owners.”
This is different from other annual filing requirements you may have, such as IRS and state income tax returns, city business license renewals, or Secretary of State annual reports. It is not an accounting or tax-related filing, simply informational.
*Some businesses may be exempt from filing. As of 3-21-25, most U.S. formed companies and persons are exempt from filing. Visit www.fincen.gov/boi for details.
What you need to do:
--> Visit www.fincen.gov/boi to file the report.
The government created an online portal so business owners can file the report themselves for FREE. We have also provided some instructions below to guide you.
It should take only 10-15 minutes and requires only basic business information such as names, address, and a form of personal identification.
Deadline for Initial Report:
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Existing companies (registered in the US before 3-21-25 ruling): April 20, 2025.
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New companies (registered on or after March 21, 2025): 30 calendar days after company creation/registration.
What information is needed to file the report:
The report asks for general information about your company and its owners/officers. You will only need the names, SSN/EIN, and address of the business and each beneficial owner. You also need to upload an identifying document for each beneficial owner, such as a copy of a driver’s license or passport.
TIP: If you own multiple companies, you can get a "FinCEN ID number" for yourself at fincenid.fincen.gov. Then, you can file the Initial Report for each company and just use that FinCEN ID number instead of entering your information all over again each time.
Company Applicant:
Companies created after 12-31-2023 must identify a “Company Applicant”. This is the individual(s) who filed or directed filing the initial formation documents for your company. For most businesses, it is their lawyer, accountant, owner, or an employee. (Check fincen.gov/boi for a detailed explanation). If our office is your Company Applicant, simply ask us to provide a FinCEN ID number for you to use.
Consequences for Non-Compliance:
The government may impose severe penalties for failing to file the report in a timely manner. It is your responsibility to satisfy filing requirements for your business on time.
What to do after filing the Initial Report?
BOI filing is NOT an annual filing requirement; however, you must file an updated report if any of the information changes (or you become exempt) within 30 days of a change.
The above is just a brief summary/explanation. We recommend you visit www.fincen.gov/boi to read the Small Business Compliance Guide for important information, definitions, deadlines, and more guidance, including detailed explanations of who/what is considered a “beneficial owner” and who is exempt.
INITIAL REPORT Online Filing Guide
Go to BOIEFILING.fincen.gov
Click “File BOIR” (bottom-left), then click “Prepare & Submit BOIR”: File Online BOIR (Web).
Below are notes and tips on a few of the questions that may not be so clear.
Step 1. Each reporting company must first file an “Initial Report” (option a) unless it is an exempt entity.
Step 5. Company Legal Name. This is the name on your business tax return. Do NOT use a DBA here.
Step 6. Here, you can list your DBA (also known as “Fictitious Business Name” or “Trade Name”).
Step 16. "Existing reporting company": check this box ONLY IF your business was formed before
1-1-2024.
--> Then you can skip Part II (#18-33).
Part II Company Applicant.
Complete this part ONLY IF your business was formed 1-1-24 or later.
* If your company applicant has a FinCEN ID, use that for #18, otherwise you will have to complete #19-33 with their information and ID.
Part III Beneficial Owner(s) Information.
A “Beneficial Owner” is anyone who either:
(a) owns or controls at least 25% ownership through equity, stock, voting rights, etc., OR
(b) exercises substantial control of the company (such as any senior officer, CEO, CFO, President, COO, LLC manager, etc.).
This is a very simplified explanation. We recommend you read the Small Business Compliance Guide under the HELP tab for a more detailed definition.
Step 36. (Optional) Enter the FinCEN ID for a Beneficial Owner if they have one. Otherwise, complete #38-51.
Steps 38-51. If no FinCEN ID, then enter information for the Beneficial Owner(s): name, address, date of birth, upload an identifying document, etc.
Repeat this for ALL Beneficial Owners. Use the blue “Add Beneficial Owner” button at the top-right to add as many owners as needed.
After submission: Save the filing confirmation.
(They won't always send you an email confirmation.)
The purpose of this courtesy notice is to inform you of possible reporting responsibilities and should not be construed as legal advice. The CTA is new and additional guidance/interpretation/changes may be issued which may impact your reporting requirements and the information above. It is your responsibility to remain updated on all applicable laws and updates.