FinCEN’s Beneficial Ownership Information reporting system has been live since January 1, 2024, and the filing deadline for companies formed before 2024 is January 1, 2025. If you have been putting off this new requirement, it is time to get it done. Here is a step-by-step walkthrough.
Who Must File
Most small LLCs, corporations, and similar entities formed by filing documents with a state secretary of state are “reporting companies” under the Corporate Transparency Act. You are likely exempt only if your company has more than 20 full-time employees AND more than $5 million in gross receipts (reported on your prior year tax return) AND a physical office in the U.S. Other exemptions apply to banks, credit unions, insurance companies, publicly traded companies, and certain regulated entities. If you do not clearly fit an exemption, you should file.
What Information You Need
For each beneficial owner (anyone who owns 25% or more of the company or exercises substantial control, such as a CEO, CFO, or managing member), gather: full legal name, date of birth, current residential address (not a P.O. box), and a government-issued photo ID (driver’s license, state ID, or passport). You will need to upload an image of the ID document.
For the company itself, you need: legal name, any trade names or DBAs, current address, state of formation, and your EIN (or SSN if you do not have an EIN).
How to File
Go to boiefiling.fincen.gov. The system is free to use. Click “File BOIR” and follow the prompts. For a single-owner LLC, the process takes about 20 minutes. Multi-member entities take longer because you repeat the beneficial owner section for each qualifying person.
After filing, you will receive a confirmation with a unique filing ID. Save this. You will need it if you ever need to update or correct your filing.
Common Questions
What if I own multiple LLCs? Each entity files separately. A holding company and its subsidiary are two separate filings.
What about trusts? If a trust owns 25% or more of the company, the individual trustees, beneficiaries, or grantors who have the power to direct the trust’s activities are the beneficial owners who must be reported.
What triggers an update? Any change in beneficial ownership information (name change, new address, new owner, change in control) must be reported within 30 days.
Do not overthink this. For most small businesses, BOI filing is a straightforward process. Get it done well before the deadline so you are not rushing at year-end.