FinCEN BOI Reporting: Important Update for U.S. Companies
by Michael R. Cahill, Esq.

***UPDATE***
The BOI reporting requirements described below no longer apply to companies created in the United States. FinCEN initially exempted domestic companies through an interim final rule effective March 26, 2025. That exemption was made permanent by a final rule published and effective August 14, 2026.
Domestic LLCs, corporations, and their beneficial owners are no longer required to file, update, or correct BOI reports. Only certain entities formed outside the United States and registered to do business here remain subject to the reporting requirements.
The original article is preserved below for historical reference, but domestic companies should not rely on its filing instructions. For current information, visit FinCEN’s official BOI webpage.
Original Filing Instructions—No Longer Applicable to Domestic Companies
In September 2022, FinCEN, a bureau of the U.S. Department of Treasury, announced its final rule requiring certain entities to report their beneficial ownership information. The BOI report was designed to provide transparency about who owns and benefits from an LLC or corporation. It requested identifying information about an entity’s beneficial owners—the individuals who directly own or control a company.
The purpose of the reporting requirement was to make it more difficult for unscrupulous individuals to hide illegal or improper gains through shell companies or other questionable ownership arrangements. It was intended to provide the U.S. government with information that could help enhance national security and protect financial systems from fraud, money laundering, drug trafficking, and other illegal activities.
The following instructions were originally published in April 2024 and are retained for historical reference only.
To get started, follow this link: File a report using the BOI E-Filing System.
Next, click the blue “File BOIR” box.
Then, click the “Prepare and Submit BOIR” bar in the File Online BOIR box. The system also offered the option of downloading a PDF, completing it offline, and uploading it with the required identification.
Here were the 15 steps:
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Assuming this was your first filing, select “Initial Report” and click “Next.”
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Check Box 3 to receive a FinCEN ID.
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In Box 5, enter the company name.
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In Box 6, add any DBA or fictitious firm name filed with the state or county. Otherwise, leave it blank.
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In Box 7, select the applicable taxpayer identification number, such as the company’s EIN or the owner’s Social Security number if the company did not have an EIN.
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In Box 8, enter the number selected in Box 7 without the hyphen.
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In Box 10a, select the United States.
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In Box 10b, select the state where the company was formed.
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In Box 11, enter the company’s address.
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Click “Next.”
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If the company existed before January 1, 2024, Box 16 could be selected so that Company Applicant information was not required. Companies created on or after January 1, 2024, were generally required to provide the Company Applicant’s name, date of birth, address, identification information, and a copy of the identification document. A FinCEN ID could also be used to provide this information.
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Part III required information about each beneficial owner. A FinCEN ID could be entered to prefill the information. Without a FinCEN ID, the filer was required to enter the owner’s identifying information.
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Box 37 could be selected if the company qualified as an exempt entity.
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Boxes 38 through 51 requested the beneficial owner’s name, date of birth, residential address, identification information, and an uploaded copy of the identification document.
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Finally, the person submitting the report entered a name and email address and submitted the filing.
About Michael R. Cahill
Mr. Cahill has spent his professional career dedicated to assisting clients with planning their estates, protecting their assets from creditors, and creating business entities to operate companies or manage investments.
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