Companies required to file a Beneficial Ownership Information report (ROIR) under the Corporate Transparency Act must share information with FinCEN about their reporting company, beneficial owners, and company applicants.
If you’re filing the BOI report yourself, the process can feel a little confusing. As you progress through the form fields, you can’t help but notice you are inputting the same data over and over again. In reality, you are, but the reason for this is you are answering questions on various parties involved and information can overlap.
What details must be included in the BOI report? Here’s a breakdown of the filing requirements.
Reporting Company
Business entities who must submit the report are considered reporting companies. Reporting companies must provide the following information about their companies:
- Full legal business name
- All DBAs, fictitious names, trade names
- Complete current U.S. address of the principal place of business (if the principal office is outside of the United States, report the primary location in the U.S. where the company conducts business instead)
- Jurisdiction of formation or registration in the U.S. (state, tribal, or foreign)
- IRS Taxpayer Identification Number (e.g., EIN)
Beneficial Owners
Beneficial owners are individuals with a controlling interest or other substantial control (direct or indirect) over the business entity. A reporting company must provide the below details about each person who is a beneficial owner of the business entity:
- The individual’s legal name
- Date of birth
- Residential street address (or the company applicant’s business address if the company applicant works in corporate formation, e.g., if they’re an attorney or corporate formation agent)
- An identifying number from an acceptable identification document (e.g., passport, driver’s license) and the state or jurisdiction that issued the identification document (The company must also provide an image of the identification document.)
Company Applicant
A company applicant is the individual who filed the business’s formation documents to legally create the entity. The following information about the entity’s company applicants must be provided in the BOI report:
- The person’s legal name
- Date of birth
- Residential street address
- An identifying number from an acceptable form of identification (e.g., driver’s license, passport) and the issuing state or jurisdiction of the identification document (The company must also provide an image of the identification document.)
CorpNet Is Here to Help!
Failing to file your BOI report on time can lead to costly penalties. CorpNet can help you file your information to FinCEN so your company fulfills this critical compliance responsibility.
Common Questions
Do all reporting companies have to provide information about their company applicant(s)?
No, only those created or registered on or after January 1, 2024 must report their company applicants.
What forms of identification are acceptable for identifying beneficial owners and company applicants?
The Corporate Transparency Act (CTA) requires one of the following types of identification for those individuals:
- A non-expired U.S. driver’s license
- A non-expired identification document issued by a U.S. state, local government, or Indian Tribe
- A non-expired U.S. passport
If an individual does not have any of the ID forms above, they may submit a non-expired passport issued by a foreign government.
What if a reporting company cannot obtain one of the forms of ID for a beneficial owner or company applicant?
Providing the individual’s unique identifying number and an image of the identification document is mandatory on the BOI report. Failing to do so may result in civil and criminal penalties, so it’s critical for reporting companies to have the full cooperation of their beneficial owners and company applicants when preparing the filing.
Does a reporting company have to report the required information each year?
The BOI is a one-time filing. However, if any reported information about the company and its beneficial owners changes, a reporting company must file an updated report within 30 days of the change. Likewise, a reporting company has up to 30 days to file a corrected BOI report if they determine any information submitted on their report was inaccurate.
What is the deadline for filing a reporting company’s first BOI report?
- Business entities created or registered in the U.S. before January 1, 2024 must file on or before January 1, 2025
- Business entities created or registered in the U.S. on or after January 1, 2024 and before January 1, 2025 must file within 90 calendar days after receiving notice that their entity’s formation or registration is effective.
- Business entities created or registered in the U.S. on or after January 1, 2025 must file within 30 days after receiving notice that their entity’s formation or registration is effective.
More BOI Information and Resources
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- The Purpose of BOI Reporting
- Consequences of Not Filing a BOI Report
- What Is a BOI Report and Do You Need to File One?
- BOI Reporting Requirements by Entity Type
- Do Inactive Business Entities Need to File a BOI Report?
- Company Applicant vs. Beneficial Owner
- Who Is a Beneficial Owner of a Business?
- Who Is Authorized to File a BOI Report?
- Is the Beneficial Owner Information Report a One-Time or Recurring Filing?
