How To File a Beneficial Ownership Report

The Corporate Transparency Act (CTA) was enacted in 2021 as a means to improve corporate transparency and help fight illegal financial activities like money laundering, terrorist financing, and tax fraud. One of the key developments from that legislation was that companies operating in or registered to do business in the United States must report information about their beneficial owners to the Financial Crimes Enforcement Network (FinCEN).

As of March 26, 2025, all entities created in the United States are no longer required to file Beneficial Ownership Information (BOI) with FinCEN. However, most foreign companies still must. Here’s what you need to know about how to file a beneficial ownership report.

Who Needs to File a BOI Report?

As of March 26, 2025, United States domestic reporting companies are no longer required to file a BOI report. However, entities formed under the law of a foreign country that are registered to do business in any state or tribal jurisdiction still must file a BOI report with the Secretary of State’s office in the state in which they’re registered.

There are 23 specific exemptions for certain types of entities. Most exemptions apply because the company is already subject to substantial federal or state regulation. Common exemptions include:

• Large operating companies: Companies that employ more than 20 full-time employees in the U.S., filed federal income tax returns demonstrating more than $5 million in gross receipts or sales, and have an operating presence at a physical office in the U.S.
• Publicly traded companies
• Banks and credit unions
• Insurance companies
• Non-profit organizations
• Governmental authorities

What Information is Required on the BOI Report?

When you file a BOI report, you’ll need to share detailed information about the reporting company, its beneficial owners, and in some cases, company applicants. This includes:

• Reporting Company Information: Full legal name and any trade names or DBAs (Doing Business As), address, jurisdiction of formation or registration, and Taxpayer Identification Number (TIN).
• Beneficial Owner Information: Name, date of birth, address, and ID for any “beneficial owner” who exercises substantial control over the reporting company or owns or controls at least 25% of ownership interests.
• Company Application Information: The same information for the individual who directly files the document that creates or registers the reporting company, if it’s different from a beneficial owner.

How to File with the FinCEN BOIR System

If your company is not exempt from filing, you can submit your BOI Report through FinCEN’s secure online filing system, the Beneficial Ownership Information Report (BOIR) system. Here’s the step-by-step process:

1. Access the system: Go to https://boiefiling.fincen.gov/ to get started.
2. Gather information: Before you begin the filing, make sure you have all the necessary information and documentation covered above.
3. Create a FinCEN ID: It’s not mandatory for the initial filing, but obtaining a FinCEN ID can make it easier to file future reports.
4. Choose your filing type: You can file an initial report, a correction, an update, or a deactivation to indicate that a company is no longer a reporting company.
5. Enter information: Fill in the online forms with info about the reporting company, beneficial owners, and company applicants, if applicable.
6. Submit the report: After you’ve certified that all information is accurate, click submit and you’ll receive a confirmation of submission.