BOI reporting corrections for errors

Any inaccuracy in a previously filed Beneficial Ownership Information (BOI) report (including company information, beneficial owner details, or company applicant data) must be corrected. A reporting company is required to correct an inaccurate BOI report no later than 30 calendar days after the date the company became aware of the inaccuracy or had reason to know of it.

While FinCEN guidance indicates that there are no penalties for filing an inaccurate BOI report provided it is corrected within 90 calendar days of when it was filed, the company must still adhere to the 30-day awareness window for corrections.

The 90-day period is discussed as a penalty mitigation window. It is important to distinguish between "updated" and "corrected" reports. "Updated" reports are used for routine changes (e.g., change of address, new beneficial owner) and must be filed within 30 days after the change occurs. "Corrected" reports specifically address inaccuracies in previously filed information and must be filed within 30 days after awareness of the inaccuracy.

Both corrections and updates must be submitted electronically via the FinCEN BOI secure e-filing portal ( https://boiefiling.fincen.gov ). If an individual uses a FinCEN identifier on a BOI report and subsequently updates their identifier information, all BOI reports that include that identifier are automatically updated to reflect the individual’s changes.

Conversely, reporting companies that provide an individual’s FinCEN identifier do not need to separately update the same data. If a company filed a BOI report and later becomes exempt, it should file an updated BOI report indicating its newly exempt status.

This updated report will only require identifying the entity and checking the exemption box. Failure to report or to update/correct within required timeframes can lead to civil and criminal penalties.

FinCEN emphasizes outreach but retains enforcement authority. Correcting within the 90-calendar-day mitigation window may help avoid penalties in some circumstances, depending on the facts and timing.

FinCEN has limited guidance on special cases such as non-cooperative beneficial owners. Practical tips from compliance and legal resources recommend documenting efforts to obtain information, establishing internal standard operating procedures (SOPs) to detect and correct errors, maintaining audit trails, and using company FinCEN identifiers where appropriate.

Practical, step-by-step process for a reporting company when an error is discovered:

Any inaccuracy in a previously filed Beneficial Ownership Information (BOI) report (including company information, beneficial owner details, or company applicant data) must be corrected. A reporting company is required to correct an inaccurate BOI report no later than 30 calendar days after the date the company became aware of the inaccuracy or had reason to know of it.

While FinCEN guidance indicates that there are no penalties for filing an inaccurate BOI report provided it is corrected within 90 calendar days of when it was filed, the company must still adhere to the 30-day awareness window for corrections.

The 90-day period is discussed as a penalty mitigation window. It is important to distinguish between "updated" and "corrected" reports. "Updated" reports are used for routine changes (e.g., change of address, new beneficial owner) and must be filed within 30 days after the change occurs. "Corrected" reports specifically address inaccuracies in previously filed information and must be filed within 30 days after awareness of the inaccuracy.

Both corrections and updates must be submitted electronically via the FinCEN BOI secure e-filing portal ( https://boiefiling.fincen.gov ). If an individual uses a FinCEN identifier on a BOI report and subsequently updates their identifier information, all BOI reports that include that identifier are automatically updated to reflect the individual’s changes.

Conversely, reporting companies that provide an individual’s FinCEN identifier do not need to separately update the same data. If a company filed a BOI report and later becomes exempt, it should file an updated BOI report indicating its newly exempt status.

This updated report will only require identifying the entity and checking the exemption box. Failure to report or to update/correct within required timeframes can lead to civil and criminal penalties.

FinCEN emphasizes outreach but retains enforcement authority. Correcting within the 90-calendar-day mitigation window may help avoid penalties in some circumstances, depending on the facts and timing.

FinCEN has limited guidance on special cases such as non-cooperative beneficial owners. Practical tips from compliance and legal resources recommend documenting efforts to obtain information, establishing internal standard operating procedures (SOPs) to detect and correct errors, maintaining audit trails, and using company FinCEN identifiers where appropriate.

Practical, step-by-step process for a reporting company when an error is discovered:

Assess whether the change requires a corrective action (due to an inaccuracy in a prior filing) or an update (due to a new event or change).

Gather current, accurate information and any supporting documentation for the corrected facts.

If an individual’s FinCEN identifier was used, confirm if that identifier has been updated by the individual, as the system may auto-update linked BOI reports. If not, coordinate with the individual to obtain updated identifier information.

Prepare and submit a corrected or updated BOIR electronically through the BOI e-filing portal within 30 days after awareness of the inaccuracy (or within 30 days after the change for updates). 5. If the inaccuracy was in a recently filed report, correct it as soon as possible. Note that correction within 90 days of the original filing may mitigate penalties; document the dates of discovery and corrective filing.

Maintain records of the correction, communications with beneficial owners, and timestamps from the BOI e-filing system. State-specific considerations for US businesses

BOI is a federal FinCEN requirement under the Corporate Transparency Act and is not a state filing obligation; therefore, state-by-state BOI correction procedures do not apply. However, state considerations may still be relevant for related filings (e.g., state annual reports, state-level beneficial ownership rules in some jurisdictions) and for determining the company’s formation law (which affects definitions like "company applicant"). Businesses should coordinate BOI reporting with state filings as needed to ensure internal records match federal submissions.