BOI compliance knowledge base for accounting teams

The BOI reporting requirement implements the Corporate Transparency Act (CTA) and is administered by FinCEN. Only entities that meet the Reporting Rule’s definition of a “reporting company” and do not qualify for an exemption must file BOI reports. This is a federal requirement (FinCEN/Treasury) rather than a state filing, though state notice practices (secretary of state/public notice) affect BOI filing deadlines for new registrations. For each beneficial owner (and in some cases company applicants), reporting companies must provide: (1) full name; (2) date of birth; (3) residential address; and (4) an identifying number from an acceptable identification document (U.S. driver’s license, state/local ID, U.S. passport, or foreign passport when no other ID), plus an image of that ID. Companies may use a FinCEN identifier (unique ID issued to an individual or reporting company) in place of repeating the four personal data items if the individual has obtained one. FinCEN began accepting reports Jan 1, 2024. FinCEN issued an interim/follow-on rule adjusting certain deadlines (notably a revision/extension in 2025): reporting companies registered to do business in the U.S. before March 26, 2025, must file by April 25, 2025; companies registered on or after March 26, 2025 have 30 calendar days after notice of effective registration to file an initial report. Earlier transitional deadlines also applied for companies created or registered in earlier windows (90 days for entities registered between Jan 1, 2024 and Jan 1, 2025, etc.). Accounting teams must map deadlines by entity formation/registration date and by state notice practice. Reporting companies must update or correct BOI reports when information changes. If an inaccuracy is discovered, companies must correct no later than 30 days after becoming aware (for discovered inaccuracies). FinCEN’s safe harbor: voluntarily correcting an inaccurate report within 90 days of the original filing’s deadline may avoid penalty (the statutory safe harbor language is limited to corrections filed within 90 days of the original filing date or deadline depending on context). The rule places the reporting responsibility on the reporting company. Willful failure to file, willfully filing false or fraudulent BOI, or willfully failing to update/correct may result in civil penalties (statutorily up to $500/day, adjusted for inflation — FinCEN noted $591 as an updated figure in guidance) and criminal penalties including imprisonment up to 2 years and/or fines up to $10,000. FinCEN has emphasized outreach and education but retains enforcement authority and considers factors in enforcement decisions. Anyone authorized by the reporting company (employees, owners, third-party service providers including accountants or formation agents) may file BOI reports on a company’s behalf. Filers must certify that information is true, correct and complete. Accounting firms may assist, but are not required (and in most cases do not themselves count as beneficial owners by virtue of providing services at arm’s length). Acceptable documents include non-expired U.S. driver’s licenses, non-expired state/local IDs, U.S. passports, and when necessary a foreign passport. FinCEN requires an image of the ID used to obtain the identifying number. Accounting teams must plan secure collection and storage of identity images and personally identifiable information (PII) and ensure secure transfer to FinCEN’s filing system when submitting. If a beneficial owner owns interests exclusively through multiple exempt entities, the names of those exempt entities may be reported instead of the individual’s information. Special rules exist for minors and company applicants; FinCEN guidance and the Small Entity Guide contain examples and checklists for these cases. FinCEN’s PRA estimates the average time to file ranges widely — ~90 minutes for simple companies to ~650 minutes for complex structures (collection, verification, preparation and filing). Expect accounting teams to need time for information collection, recordkeeping, identity verification and coordination with owners and formation agents. Practical guidance and actionable items for accounting teams (knowledge-base content recommendations): 1. Create a BOI intake checklist and form that collects the exact FinCEN-required fields (beneficial owner full name, DOB, residential address, ID type & number, image of ID, company applicant info if applicable), plus contact info, consent/authorization text and a record of date(s) requested and responses. 2. Map entity inventory: build or extract a current list of all client entities (LLCs, corporations, similar entities), formation/registration dates, jurisdiction of formation and public notice timing (how/when the secretary of state publishes), and current exemption status. Use this to compute each entity’s BOI deadline. 3. Establish roles and responsibilities: assign a BOI compliance owner in accounting (or a cross-functional owner including legal), define who will collect, verify and file BOI, and whether filings will be done in-house or delegated to third-party service providers. 4. Identity verification process: define acceptable documents, require image capture and confirmation, implement secure upload methods (encrypted portals), and record objective evidence of verification in the file (and if relying on third-party verification, maintain vendor records). 5. Recordkeeping and retention: store BOI collection records, ID images, consents and correspondence securely; maintain audit trails of filings and updates; retain records in line with internal policy and applicable law (and document attempts to obtain withheld information for enforcement defensibility). 6. Update and correction workflows: create triggers to update BOI reports within 30 days of known changes, and develop a remediation workflow to file corrections within 90 days when appropriate to protect the safe harbor. 7. State-specific handling: capture secretary-of-state/public-notice practices to determine when a newly registered company’s 30-day (post-March 26, 2025) or 90-day (earlier windows) clock begins; otherwise the requirement is federal and uniform. Note there is no separate state BOI database currently — reporting goes to FinCEN’s federal system. 8. Training and communications: prepare client-facing communications (templates) for requesting BOI info from beneficial owners, train staff on confidentiality and PII handling and on penalties and timelines. 9. Consider software and vendors: evaluate entity-management and KYC tools that can collect required fields, store PII securely, track deadlines and integrate with FinCEN filing mechanisms or support batch reporting and audit logs. 10. Coordination with legal and formation agents: coordinate with attorneys/formation service providers on company applicants (they must provide business address if they work in formation) and on cases where ownership is held through trusts or exempt entities; involve counsel for complex ownership chains. 11. Documentation for due diligence: record refusal or inability of beneficial owners to provide information, and steps taken to obtain it; maintain logs to support defensible positions if enforcement is contemplated.