Beginning in 2024, the Corporate Transparency Act introduced a new rule for small businesses: registered companies are required to file a beneficial ownership information report. That’s right — another form to file. But before you worry about being overwhelmed by paperwork, rest assured that this report is very manageable as long as you know what to expect.
In this guide, we’ll walk you through the essential steps you’ll need to follow to file the beneficial ownership information report efficiently and on time.
The beneficial ownership information report (or BOIR) form is an essential filing required by the Corporate Transparency Act. A wide variety of business entities, particularly limited liability companies (LLCs) and corporations, need to file a beneficial ownership information report. You can learn more about it in our beneficial ownership report guide.
How to Complete the Beneficial Ownership Information Form
FinCEN offers you two primary methods to file your BOI report: filing online or uploading a completed PDF version of the BOIR form. We’ll walk you through how to complete each version.
Determine if you need to report beneficial ownership information
Before you file your form, you need to check if you’re even required to file a BOI report. Many small business entities, like LLCs and corporations, need to file by default. FinCEN also requires any other entities that file registration paperwork with their Secretary of State or similar U.S. government office to file a BOIR.
However, FinCEN does categorize some entities as exempt (23 in total). We won’t list all of them here; you can read the full exemption list in the Small Entity Compliance Guide. But as a general rule, business entities that register their ownership information elsewhere usually don’t have to file a beneficial ownership report because that info is already on file. For example, publicly traded companies don’t file a BOI report because they’ve already registered with the Securities and Exchange Commission.
If your business doesn’t qualify as exempt under the Corporate Transparency Act, FinCEN regards you as a reporting company and will expect your report.
Verify the due date for your BOIR
The Corporate Transparency Act sets out pretty clear due dates for your annual report, but they vary slightly depending on when you create (or created) your business. If you created your business before January 1, 2024, your report must be filed sometime during 2024. Reporting companies created during 2024 have 90 days after receiving “actual or public notice” (i.e., news that their LLC or corporation was approved).
Finally, businesses that register after January 1, 2025, will have 30 days to file their BOIR. Be sure to file on time to avoid penalties and fines.
Gather necessary information
Regardless of whether you file the online or PDF version of the form, you’ll be expected to provide some specific information about your beneficial owners and your company applicants. Let’s walk through who those people are and what information you’ll need to provide.
Beneficial Owners
Under the terms of the Corporate Transparency Act, the following people qualify as a beneficial owner of a company. A beneficial owner is anyone who:
- Owns 25% or more of the company
- Receives substantial economic benefit from the business
- Exercises substantial control over the company
While there are a few exemptions, the majority of LLC members or corporate shareholders who meet the above criteria will qualify as beneficial owners of a reporting company.
Company Applicants
The Corporate Transparency Act also requires reporting companies to list information for their company applicants. A company applicant is the person (or persons) responsible for filing business formation documents on a reporting company’s behalf. You must report at least one company applicant but can’t report more than two.
One important note: company applicant information is only required for business entities formed on or after January 1, 2024. If you created your business before that, you won’t have to list company applicants.
Beneficial Owner Information and Reporting Company Information to Gather
Now that you know who your beneficial owners and company applicants are, it’s time to gather some information about them. Here’s what you need to compile for each individual:
- Their legal name
- Date of birth
- Current address (residential address or business address)
- An identification number from a non-expired document like a U.S. passport, state ID, or foreign passport
- An image of that ID
You’ll also need to get this information about your company:
- The full legal business name
- Any trade name or DBA the business holds
- Current business address (must be in the U.S.)
- Jurisdiction where the business was formed
- Your taxpayer identification number (foreign reporting company) or employer identification number (domestic reporting company)
Be sure to have all this information handy as you move on to the next steps.
How to Complete the Beneficial Ownership Information Report Online
FinCEN makes it possible to file the beneficial ownership report entirely online if you wish. This is probably the most streamlined version of the form, but even then, there are important steps to complete. Here’s what to expect.
Step 1: Indicate what type of form you’re filing
Your first step will be to tell FinCEN if you’re filing an initial report, correcting a prior report, updating a prior report, or filing for a new exemption from the BOIR. If this is your first report for this reporting company, you’ll check the box for “initial report.” Reporting companies that are updating or correcting information will need to check the matching boxes.
Step 2: Request a FinCEN identifier (optional)
If you wish, you’ll be prompted to check a box to request a FinCEN identifier. This identifier is a unique number that you can use for the BOIR. Some small business owners find this number helpful because they can list it instead of other personal information on BOI reports. It adds a layer of privacy, much like an EIN can help you avoid using your Social Security number on certain forms.
You do not have to request a FinCEN identifier, so if you don’t want one, skip this step.
Step 3: Fill in information about your reporting company
Remember the information you gathered above about your business? Now’s the time to fill it in. Here’s the full rundown of which info you’ll need to provide:
- Whether you’re a foreign pooled investment vehicle
- Your full legal business name
- Any alternate names: DBAs, trade names, etc.
- Your taxpayer identification number or EIN
- The jurisdiction that issued your taxpayer ID (Foreign reporting companies only)
- Jurisdiction where you first formed your business
- Complete current U.S. address
- Whether you’re a new or existing reporting company (“new” applies to businesses created on or after January 1, 2024)
Be sure to fill in all this information carefully so you don’t make any mistakes.
Step 4: Provide information about your company applicants
This step only applies to businesses created on or after January 1, 2024. So if you checked “existing reporting company” at the end of Step 3, move on to Step 5.
The form will ask you for at least one company applicant, but you can’t list more than two. For each applicant, you can provide a FinCEN if they have one. If not, you’ll provide this info:
- Their legal name
- Their date of birth
- Their business address or residential address
- A valid ID number and the jurisdiction that issued the ID
- An electronic photo upload of that ID
Step 5: Provide beneficial owner information
All reporting companies will complete this step. If your beneficial owners have FinCEN identifiers, you can list those numbers on the form. If not, you’ll need to list all the following information for each beneficial owner:
- If the beneficial owner has ownership through an exempt entity: the legal name of the exempt entity
- Legal name of the beneficial owner (or entity)
- Date of birth
- Residential address
- Identifying document number from a valid ID and the jurisdiction that issued it
- An electronic photo upload of the ID
If one of the company’s beneficial owners is a minor child, the child’s parent or legal guardian’s information should be listed in this section instead. If you need to report more owners or fewer owners than the form initially provides, hit the “+” or “-” button at the top of the section to add or remove sections.
Step 6: Review the information and submit
Before you hit “submit,” please go back and check that all of the information you’ve provided is correct. And double-check that you haven’t overlooked any sections marked with a red asterisk. While you can correct mistakes later on, it’s easiest to just check everything from the get-go.
Once you’re sure that all your information is correct and complete, you can click submit. If you requested a FinCEN in your application, you’ll receive it right away.
How to Complete the BOIR Form by PDF
If you’d prefer to download a PDF BOIR form and upload it, you can do so. Here’s how it’s done.
Step 1: Install Adobe Reader
If you already have the latest Adobe Reader, you can complete this step. If not, you’ll need to download the software and install it. You’ll use this platform to fill in the blanks; FinCEN will not accept the form if you print it out and fill it in by hand. You must type in the information directly through Adobe.
Step 2: Download the PDF BOIR
On the FinCEN website, head to the BOI E-Filing system and hit the “File a BOIR” button. On the second page, you’ll hit “Prepare BOIR” under the “File PDF BOIR” section. This will download the PDF for you.
Step 3: Fill in the BOIR form
If your browser doesn’t automatically open Adobe for you, head to your downloads file and open the newly downloaded form (be sure to open it using Adobe Reader). When you open the form, you’ll see four tabs at the top: Home, Reporting Company, Company Applicants, and Beneficial Owners.
Click on each tab individually and type in the requested information (more details above). As you go, you can use buttons on the homepage to streamline the process. You can hit “Validate” to make sure you’ve formatted things correctly and filled in every required section. “Save” will let you make a localized copy of the report to protect your progress. “Finalize” locks the form so it can’t be edited (and makes an “Edit form” button appear if you need to make corrections.
When you’re almost ready to submit, validate the form and then finalize and save it once you’ve made any required changes. From here, you can print off a copy of the form for your records (optional). This will activate a “Ready to File” button.
Step 4: Submit the BOIR form
Clicking on the “Ready to File” button will automatically take you to the submission form. Alternatively, you can save the file and upload it directly to the “Submit BOIR” tab of the E-filing platform.
On the submission page, you’ll be asked to provide your name and email address. You’ll also be asked to certify that the information is correct and complete a captcha to ensure you’re not a robot. After that, you can submit the form.
If there were any errors, your report will be rejected. An accepted report will give you a “Submission Status Confirmation” page.
Common Mistakes
As with any formal paperwork, you’ll find it’s possible to make mistakes with the Beneficial Ownership Information report. Here are some common mistakes you should avoid:
- Not including company applicants (entities formed after January 1, 2024, only)
- Leaving off additional trade names or DBAs the business has
- Using a prohibited format for pictures of your ID (JPG/JPEG, PDF, and PNG are the only acceptable files)
- Using a file that’s too big for ID pictures (cannot exceed 4MB)
- Mistyping beneficial ownership information: transposing numbers in an address, misspelling a name, etc.
- Leaving out any field marked with a red asterisk (online filings)
- Using prohibited words in text fields: AKA, Same as above, other, same, not applicable, etc.
If you do make a mistake, you can use the filing system again to correct your information. When you discover an error in a filed report, be sure to correct it within 30 days. That way, you’ll avoid serious penalties.
Try ZenBusiness
Still worried about completing your beneficial ownership information report? We can help. Our ZenBusiness Beneficial Ownership Filing service can help you comply with the Corporate Transparency Act. We can also help you start and maintain your business. Whether you need help starting an LLC or corporation, a platform to manage your finances, or peace of mind that your business is compliant, we can help. Let us handle the red tape side of things so you can focus on growing your business.
Disclaimer: The content on this page is for information purposes only and does not constitute legal, tax, or accounting advice. If you have specific questions about any of these topics, seek the counsel of a licensed professional.
