Yesterday, on December 23rd, 2024, a court ruling reinstated the reporting requirement that has existed for all of 2024. This rule had been suspended on December 3, 2024. Additionally, language that would have delayed the filing requirements for one year did not make it in the stripped-down budget bill that passed over the weekend.
As of today, most corporations and LLCs have until January 13, 2025 to file the report or face severe penalties.
Who Must File a BOI Report?
- Corporations, limited liability companies (LLCs), and other similar entities created by filing a document with a secretary of state or similar office.
- Foreign entities that register to do business in the United States.
Please see our original post on January 26th here for details: for more details on reporting requirements. More information is available on the official FinCEN website.
Here are the current filing deadlines:
- Companies created or registered prior to January 1, 2024 have until January 13, 2025 to file.
- Companies created or registered on or after September 4, 2024 that had a filing deadline between December 3, 2024 and December 23, 2024 have until January 13, 2025 to file.
- Companies created or registered on or after December 3, 2024 and on or before December 23, 2024 have an additional 21 days from their original filing deadline to file.
- Companies that qualify for disaster relief may have extended deadlines that fall beyond January 13, 2025. These companies should abide by whichever deadline falls later.
- Companies that are created or registered on or after January 1, 2025 have 30 days to file.
How to File
BOI reports must be filed electronically. FinCEN’s e-filing portal, available at https://boiefiling.fincen.gov/fileboir, provides two methods to submit a report: (1) by filling out a web-based version of the form and submitting it online, or (2) by uploading a completed PDF version of the BOI report. Some third-party service providers may also offer the ability to file the BOI report through their software. The person who submits the BOI report will need to provide their name and email address to FinCEN. There is no fee for filing the report.
If there is a change to previously reported information about the reporting company or its beneficial owners, an updated report must be filed within 30 days of the change. So, your company must implement a system to identify reportable changes and file an updated report with FinCEN in a timely manner.
If you do not want to file on your own, you can visit CorpNet which offers a service for BOI reporting.
If you have specific questions, please contact your attorney or go to fincen.gov/boi for more information.
