BOI compliance guides for first-time business owners

As of March 26, 2025, domestic US entities, including LLCs formed in the US, are exempt from Beneficial Ownership Information (BOI) reporting under the Corporate Transparency Act (CTA) due to FinCEN’s interim final rule.

This is a crucial update for first-time founders, as most new domestic LLCs currently do not need to file BOI reports to FinCEN. The CTA initially aimed to combat money laundering by requiring BOI reporting.

However, the March 2025 interim final rule narrowed its scope to primarily foreign reporting companies. Therefore, foreign entities registered in the U.S. (and certain other non-exempt categories) must still comply.

For foreign entities registered before March 26, 2025, the initial filing deadline is April 25, 2025. For registrations on or after March 26, 2025, initial BOI reports must be filed within 30 calendar days after receiving notice of effective registration.

Even if currently exempt, first-time US business owners should take practical steps:

As of March 26, 2025, domestic US entities, including LLCs formed in the US, are exempt from Beneficial Ownership Information (BOI) reporting under the Corporate Transparency Act (CTA) due to FinCEN’s interim final rule.

This is a crucial update for first-time founders, as most new domestic LLCs currently do not need to file BOI reports to FinCEN. The CTA initially aimed to combat money laundering by requiring BOI reporting.

However, the March 2025 interim final rule narrowed its scope to primarily foreign reporting companies. Therefore, foreign entities registered in the U.S. (and certain other non-exempt categories) must still comply.

For foreign entities registered before March 26, 2025, the initial filing deadline is April 25, 2025. For registrations on or after March 26, 2025, initial BOI reports must be filed within 30 calendar days after receiving notice of effective registration.

Even if currently exempt, first-time US business owners should take practical steps:

Confirm entity status

Determine if your entity is domestic or foreign and if any statutory exemptions apply.

Maintain ownership records

Keep up-to-date internal records of beneficial ownership (names, dates of birth, addresses, SSNs/TINs, nature of control) as good corporate practice and in case rules change.

Obtain identifiers

Secure an EIN/Tax ID, and consider creating a FinCEN ID to be prepared for future filing requirements.

Assign responsibility

Designate an individual or advisor to monitor BOI developments and handle filings if needed.

Monitor updates

Stay informed by monitoring FinCEN and Treasury updates, as well as state Secretary of State notices. Subscribe to FinCEN updates.

Foreign entity compliance

If you own a foreign entity registered in the U.S., work with legal counsel or a compliance provider to prepare and file via the FinCEN BOI E-Filing System.

Correct errors

Promptly correct any errors or omissions within 90 days of a deadline to mitigate enforcement risks. State Secretary of State offices are not responsible for BOI filings; they typically issue notices directing businesses to FinCEN guidance. Always check your state’s Secretary of State website for local notices and information regarding business registration timing, which impacts FinCEN’s filing windows for foreign reporting companies. For further information, refer to primary sources such as the FinCEN BOI main page, FinCEN FAQs, the Small Entity Compliance Guide, and the BOI E-Filing system. The IRS also provides an explanatory page for small businesses, and reputable law firm summaries offer deeper insights.