BOI compliance for content creators

BOI compliance for content creators As of the latest FinCEN guidance and rulemaking (March 2025), FinCEN issued an interim final rule that removes the requirement for domestic (U.S.-created) companies and U.S. persons to report Beneficial Ownership Information (BOI) under the Corporate Transparency Act; the reporting-company definition was revised to cover only certain foreign entities that register to do business in the U.S. (often called foreign reporting companies).

Therefore, most U.S. content creators who form domestic LLCs or corporations are currently not required to file BOI reports with FinCEN. However, foreign entities registered in a U.S. state may still have filing obligations and FinCEN established new deadlines (for many such foreign entities, April 25, 2025, for prior registrations, or 30 days after registration for later ones).

Despite the interim final rule, earlier guidance and the Small Entity Compliance Guide (version March 2025) originally described requirements for domestic reporting companies (effective Jan 1, 2024, with phased deadlines), which means some public-facing materials and secondary sources may continue to reference the original domestic reporting timeline.

The legal landscape included litigation and temporary injunctions earlier in 2024–2025; practitioners should monitor FinCEN and DOJ notices for any further changes or litigation outcomes. Practical guidance for content creators today (given the current rule): 1.

Determine whether your entity is a domestic or foreign entity. Domestic U.S.-formed LLCs and corporations: currently exempt from BOI reporting to FinCEN under the March 2025 interim final rule.

Foreign entities that have registered to do business in the U.S. may still need to file BOI reports; check the registration date and FinCEN deadlines. As of the latest FinCEN guidance and rulemaking (March 2025), FinCEN issued an interim final rule that removes the requirement for domestic (U.S.-created) companies and U.S. persons to report Beneficial Ownership Information (BOI) under the Corporate Transparency Act; the reporting-company definition was revised to cover only certain foreign entities that register to do business in the U.S. (often called foreign reporting companies).

Therefore, most U.S. content creators who form domestic LLCs or corporations are currently not required to file BOI reports with FinCEN. However, foreign entities registered in a U.S. state may still have filing obligations and FinCEN established new deadlines (for many such foreign entities, April 25, 2025, for prior registrations, or 30 days after registration for later ones).

Despite the interim final rule, earlier guidance and the Small Entity Compliance Guide (version March 2025) originally described requirements for domestic reporting companies (effective Jan 1, 2024, with phased deadlines), which means some public-facing materials and secondary sources may continue to reference the original domestic reporting timeline.

The legal landscape included litigation and temporary injunctions earlier in 2024–2025; practitioners should monitor FinCEN and DOJ notices for any further changes or litigation outcomes. Practical guidance for content creators today (given the current rule): 1.

Determine whether your entity is a domestic or foreign entity. Domestic U.S.-formed LLCs and corporations: currently exempt from BOI reporting to FinCEN under the March 2025 interim final rule.

Foreign entities that have registered to do business in the U.S. may still need to file BOI reports; check the registration date and FinCEN deadlines. Maintain accurate, contemporaneous ownership and control records for your entity (membership ledgers, operating agreements, ownership percentages, KYC).

If the law changes or the company becomes a foreign reporting company, you’ll need these records to prepare a BOI report quickly. Understand who would be a “beneficial owner” or “company applicant” under the BOI rules (substantial control or >=25% ownership; company applicants are individuals who file the document creating the company or register it).

Collect names, date of birth, address, identification numbers, and copies of identifying documents if asked. Even if you are not required to file today, collecting this information now reduces future compliance burden. 4.

If you are a foreign entity registered in the U.S., or you have foreign owners that change entity status, follow FinCEN filing deadlines (e.g., April 25, 2025 for prior-registered foreign entities per the March 26, 2025 Federal Register/FinCEN materials) and file through the BOI E-Filing system when required.

Use a lawyer/CPA for complex ownership chains, trusts, or nominee arrangements. State-level requirements many states require LLC annual reports and may require member/manager names and addresses on filings.

Some states’ annual reports can disclose owner/manager info publicly; be aware of state-specific disclosure that can affect privacy considerations for creators. Check your Secretary of State for specifics.

Privacy and risk do not rely on improper nominee arrangements to avoid reporting; consult counsel. Keep sensitive ownership data secure.

Consider obtaining a FinCEN identifier (when reporting) and update FinCEN within required timelines if you later file. Penalties willful failure to report, filing false information, or causing a company not to file may create civil and/or criminal liability.

Even if currently exempt, maintain good records and comply with state obligations.

BOI compliance for content creators As of the latest FinCEN guidance and rulemaking (March 2025), FinCEN issued an interim final rule that removes the requirement for domestic (U.S.-created) companies and U.S. persons to report Beneficial Ownership Information (BOI) under the Corporate Transparency Act; the reporting-company definition was revised to cover only certain foreign entities that register to do business in the U.S. (often called foreign reporting companies).

Therefore, most U.S. content creators who form domestic LLCs or corporations are currently not required to file BOI reports with FinCEN. However, foreign entities registered in a U.S. state may still have filing obligations and FinCEN established new deadlines (for many such foreign entities, April 25, 2025, for prior registrations, or 30 days after registration for later ones).

Despite the interim final rule, earlier guidance and the Small Entity Compliance Guide (version March 2025) originally described requirements for domestic reporting companies (effective Jan 1, 2024, with phased deadlines), which means some public-facing materials and secondary sources may continue to reference the original domestic reporting timeline.

The legal landscape included litigation and temporary injunctions earlier in 2024–2025; practitioners should monitor FinCEN and DOJ notices for any further changes or litigation outcomes. Practical guidance for content creators today (given the current rule): 1.

Determine whether your entity is a domestic or foreign entity. Domestic U.S.-formed LLCs and corporations: currently exempt from BOI reporting to FinCEN under the March 2025 interim final rule.

Foreign entities that have registered to do business in the U.S. may still need to file BOI reports; check the registration date and FinCEN deadlines. As of the latest FinCEN guidance and rulemaking (March 2025), FinCEN issued an interim final rule that removes the requirement for domestic (U.S.-created) companies and U.S. persons to report Beneficial Ownership Information (BOI) under the Corporate Transparency Act; the reporting-company definition was revised to cover only certain foreign entities that register to do business in the U.S. (often called foreign reporting companies).

Therefore, most U.S. content creators who form domestic LLCs or corporations are currently not required to file BOI reports with FinCEN. However, foreign entities registered in a U.S. state may still have filing obligations and FinCEN established new deadlines (for many such foreign entities, April 25, 2025, for prior registrations, or 30 days after registration for later ones).

Despite the interim final rule, earlier guidance and the Small Entity Compliance Guide (version March 2025) originally described requirements for domestic reporting companies (effective Jan 1, 2024, with phased deadlines), which means some public-facing materials and secondary sources may continue to reference the original domestic reporting timeline.

The legal landscape included litigation and temporary injunctions earlier in 2024–2025; practitioners should monitor FinCEN and DOJ notices for any further changes or litigation outcomes. Practical guidance for content creators today (given the current rule): 1.

Determine whether your entity is a domestic or foreign entity. Domestic U.S.-formed LLCs and corporations: currently exempt from BOI reporting to FinCEN under the March 2025 interim final rule.

Foreign entities that have registered to do business in the U.S. may still need to file BOI reports; check the registration date and FinCEN deadlines. Maintain accurate, contemporaneous ownership and control records for your entity (membership ledgers, operating agreements, ownership percentages, KYC).

If the law changes or the company becomes a foreign reporting company, you’ll need these records to prepare a BOI report quickly. Understand who would be a “beneficial owner” or “company applicant” under the BOI rules (substantial control or >=25% ownership; company applicants are individuals who file the document creating the company or register it).

Collect names, date of birth, address, identification numbers, and copies of identifying documents if asked. Even if you are not required to file today, collecting this information now reduces future compliance burden. 4.

If you are a foreign entity registered in the U.S., or you have foreign owners that change entity status, follow FinCEN filing deadlines (e.g., April 25, 2025 for prior-registered foreign entities per the March 26, 2025 Federal Register/FinCEN materials) and file through the BOI E-Filing system when required.

Use a lawyer/CPA for complex ownership chains, trusts, or nominee arrangements. State-level requirements many states require LLC annual reports and may require member/manager names and addresses on filings.

Some states’ annual reports can disclose owner/manager info publicly; be aware of state-specific disclosure that can affect privacy considerations for creators. Check your Secretary of State for specifics.

Privacy and risk do not rely on improper nominee arrangements to avoid reporting; consult counsel. Keep sensitive ownership data secure.

Consider obtaining a FinCEN identifier (when reporting) and update FinCEN within required timelines if you later file. Penalties willful failure to report, filing false information, or causing a company not to file may create civil and/or criminal liability.

Even if currently exempt, maintain good records and comply with state obligations.