BOI reporting for companies changing their names

Summary of findings and actionable guidance for U.S. businesses changing legal names (BOI/FinCEN): Key conclusions (current as of 2026-01-03): - FinCEN’s March 26, 2025 interim final rule (IFR) narrowed the scope of BOI reporting under the Corporate Transparency Act so that only foreign entities that register to do business in the U.S. ("foreign reporting companies") remain required to file BOI with FinCEN.

Domestic entities (entities created by filing with a U.S. Secretary of State or similar office) were exempted and are no longer required to report BOI or to update or correct BOI previously reported to FinCEN. (Federal Register; FinCEN press release; FinCEN BOI page.) - For entities that remain reporting companies (foreign reporting companies), FinCEN’s rule and guidance require reporting companies to file updated BOI reports when any previously reported information changes — including a legal name change — and to do so no later than 30 days after the change.

FinCEN’s Small Entity Compliance Guide and BOI FAQs give examples and state the 30-calendar-day update requirement. (FinCEN FAQs; Small Entity Compliance Guide.) Practical steps/checklist for a company that changes its legal name (what US business owners and LLC founders should do):

Determine whether you are subject to FinCEN BOI reporting now

confirm whether your company is a "domestic" company (created under U.S. law) or a "foreign reporting company" (formed under foreign law and registered to do business in the U.S.). The IFR made domestic companies exempt; foreign reporting companies still must comply. (FinCEN IFR/press release.)

If you are a foreign reporting company required to report BOI

- File an updated BOI report with FinCEN within 30 days of the name change. Use the BOI E‑Filing System (boiefiling.fincen.gov) or the PDF upload option; the updated report should include the new legal name and all previously reported information (updated as needed). (FinCEN FAQs; BOIR Filing Instructions.) - If the entity underwent a conversion/merger/other corporate action that creates a new reporting company under state law, that event may trigger an initial BOI filing instead of (or in addition to) an update — check state conversion law and FinCEN guidance; when in doubt consult counsel. (FinCEN FAQs; law firm summaries.)

If you are a domestic company (exempt under the IFR)

- You are not required to file or update BOI with FinCEN and FinCEN’s IFR states domestic reporting companies "do not have to report BOI to FinCEN, or update or correct BOI previously reported to FinCEN." Nevertheless, maintain records of any BOI previously filed (if you filed before the IFR) and monitor future regulatory developments. (Federal Register; FinCEN announcement.)

Regardless of FinCEN obligations, update state- and other government-level records and third parties

- File required amendment/statement of information/registration paperwork with your Secretary of State or similar office to reflect the name change (the state filing triggers and forms vary by state). Update any assumed name/DBA registrations as appropriate. (State filing obligations are separate from BOI; see law firm/practical guidance.) - Update IRS/Employer Identification Number records, business licenses, bank accounts, contracts, vendor/customer accounts, payroll providers, registered agent information, and any professional or licensing boards. Notify your bank and update merchant/acquirer records to avoid operational disruption.

When conversions or changes of jurisdiction occur

watch for additional BOI triggers - If a conversion (e.g., corporation → LLC) or a change in jurisdiction of formation occurs and state law treats that conversion as creating a new entity, FinCEN guidance explains that the conversion may create a new reporting company (which could trigger an initial BOI filing) or at minimum will require an updated BOI report if the company’s previously reported information changes (like name or jurisdiction). Review state conversion rules and FinCEN guidance. (FinCEN FAQs; Seyfarth/Ballard analyses.)

Practical filing logistics and evidence

use FinCEN’s BOI e-filing portal and required attachments - FinCEN provides an e-filing portal and a fillable PDF option; filing instructions and the BOI Small Entity Compliance Guide explain how to submit initial, updated, and corrected reports and when images (e.g., new ID documents for individuals using FinCEN identifiers) must be submitted. (BOIR Filing Instructions; Small Entity Compliance Guide.)

Penalties, enforcement, and recordkeeping - Historically the CTA included civil and criminal penalties for willful noncompliance, and FinCEN’s guidance set update timelines and expectations. However, FinCEN’s IFR and related FinCEN announcements relieved domestic entities from continuing reporting obligations and signaled limited enforcement against domestic companies; foreign reporting companies remain within scope. Entities should retain records and seek legal advice as enforcement posture and rules could change. (FinCEN press release; Federal Register; law firm alerts.)