As of January 1, 2024, the Corporate Transparency Act (CTA) established beneficial ownership information (BOI) reporting requirements. Following FinCEN's March 26, 2025 interim final rule, only certain foreign entities registered to do business in the United States remain subject to BOI reporting. Affected companies must submit a BOI report to the Financial Crimes Enforcement Network (FinCEN), or they risk incurring significant penalties.

This guide dives into the key components of beneficial ownership reporting to help you meet all the necessary requirements. You'll learn what the report should include, where and how to file it, and how Harbor Compliance makes the reporting process effortless.

What Is a Beneficial Ownership Information Report (BOIR)?

A beneficial ownership information report (BOIR) is a document that includes identifying information about a company's beneficial owners. Under FinCEN's interim final rule issued in March 2025, BOIRs are now required only for certain foreign entities formed outside the United States and registered to do business in a U.S. state or Tribal jurisdiction. U.S.-formed entities and U.S. persons are exempt from BOI reporting. For foreign reporting companies that are required to file, the BOIR may also include information about company applicants, as applicable under current rules.

The CTA defines a beneficial owner as an individual who either has substantial control over a company or owns at least 25% of its ownership interests. This implies your company might have various beneficial owners, such as:

• Senior officers
• Large shareholders
• Important decision-makers

What is a Company Applicant?

Company applicants are defined a bit more precisely and split into two types:

1. An individual who directly filed a document that formed the company
2. An individual who was responsible for directing and controlling the filing (only applicable if more than one person participated in the company's registration)

Company applicants need only be included in BOIRs submitted by companies formed or registered to do business in the US in 2024 or later.

When you identify beneficial owners and company applicants (if they're required for your company), you need to gather the following information on each individual:

• Full legal name
• Date of birth
• Complete current address
• Picture, unique number, and issuing jurisdiction of a driver's license, passport, or another identification document issued by the state, tribe, or local government

List the above details for each necessary individual in your BOIR, and you can submit it to FinCEN.

Beneficial Ownership Information Reporting (BOIR) Requirements

Besides the information you may include in a BOIR, there are several key details to understand about the reporting process. One important aspect is determining whether your organization qualifies as a reporting company under the Corporate Transparency Act (CTA), as not all organizations are affected.

Reporting companies now include only certain foreign entities formed under the law of another country and registered to do business in a U.S. state or Tribal jurisdiction. U.S.-formed entities and U.S. persons are exempt from BOI reporting. The CTA previously exempted 23 types of legal entities from reporting, and these exemptions continue to apply for foreign entities. For a detailed list of exemptions and their qualification criteria, refer to FinCEN's Small Entity Guide.

While initial filing deadlines no longer apply for domestic entities, foreign reporting companies that are required to file BOIRs had specific deadlines in 2025. These deadlines may provide context for voluntary reporting or historical reference:

Formation Date	BOI Reporting Timeframe
Registered before March 26, 2025	Filed by April 25, 2025
Registered on or after March 26, 2025	Within 30 days of receiving notice that registration is effective

FinCEN will not enforce penalties or fines against U.S. citizens, domestic reporting companies, or their beneficial owners.

Understanding BOI Reporting with FinCEN

With the interim final rule issued by FinCEN in March 2025, U.S. companies and their beneficial owners are no longer required to report BOI under the Corporate Transparency Act. Only certain foreign entities registered to do business in the U.S. remain subject to BOI reporting requirements.

For these foreign reporting companies, FinCEN still provides guidance on organizing and submitting information efficiently:

1. Start early—Collecting information from beneficial owners and company applicants can take time, so plan ahead to ensure accuracy.
2. Avoid last-minute filing—Submitting information in a rushed timeframe can complicate the process, even though U.S. companies are now exempt.
3. Delegate the process—Foreign entities can streamline reporting by working with a trusted BOI reporting service provider if needed.

U.S. companies and their beneficial owners are fully exempt from reporting and will not face any BOI-related penalties or fines.

Explore BOI Reporting Support

U.S. companies and their beneficial owners are now fully exempt from BOI reporting under the Corporate Transparency Act. However, foreign entities that qualify as reporting companies and are not exempt may still choose to submit BOI reports. Our team can help simplify this process for those entities, ensuring accurate submissions and the ability to file reports efficiently once all necessary documents are collected.

Order the BOI Reporting Service Here

How To File a BOI Report (BOIR)

FinCEN offers an online filing system, the Beneficial Ownership Secure System (BOSS), for submitting BOI reports. This system helps ensure information stays protected and can be updated as needed. Filing an initial BOI report is now only relevant for foreign entities that meet the current definition of a reporting company. These entities are also responsible for updating FinCEN if there are changes to their list of beneficial owners or other required company information. Updates must generally be submitted within 30 days of any change. U.S.-formed companies and their owners are no longer required to file BOI reports, freeing them from these obligations. For foreign entities seeking a more streamlined approach, services like Harbor Compliance can assist with gathering and submitting the necessary information.

Harbor Compliance—BOI Reporting Made Easy

If you don't have the bandwidth to deal with the CTA requirements on your own, Harbor Compliance is here to help. Our BOI Reporting Service ensures accurate reports and timely updates with little work on your part, saving you a significant amount of time and energy you can spend on impactful work.

If you engage with us, we'll gather all the necessary information and submit it to FinCEN on your behalf. We'll then provide ongoing support to ensure up to four corrections and updates per year are handled swiftly, minimizing your risk of violations and penalties.

All reporting companies can leverage the BOI Reporting Service, regardless of their type and structure. Whether you run a small business, multinational company, or nonprofit that isn't 501(c) exempt, our team can take BOI reporting off your plate.

Reporting BOI Yourself vs. Partnering With Harbor Compliance

According to FinCEN's estimates, submitting a BOIR can take up to three hours per entity. It's a time-consuming task, especially if you run a multi-entity organization. If you outsource reporting to us, you can avoid such waste and have peace of mind knowing that your report is handled by a team of experts.

More importantly, filing the initial report is only the first (and simpler) step of the reporting process. All BOI must be kept current and accurate, so you must continuously be on the lookout for changes in your company's ownership structure and beneficial owners' information. Harbor Compliance does the following to make updates effortless:

1. We send you automated periodic reminders to check if your BOI needs to be updated, so you don't need to worry about the threat of unreported changes.
2. When any relevant information is changed, we submit an updated BOI on your behalf, sparing you the hassle of doing so independently.

You can also sign up for the optional Records Manager, which lets you keep track of important data, such as:

• Corporate records
• Board meetings and minutes
• Leadership and ownership information

By centralizing all this information, you'll avoid complex tracking systems that might lead to crucial data slipping through the cracks.

How To Order Our BOI Reporting Service

You can order our service online by completing a simple wizard. First, choose from the following options depending on your needs:

1. Single business
2. Multiple entities

You'll then be taken to a form to enter your contact information and company details. Complete the form and check-out, and we'll take it from there.

After gathering the necessary information, we'll submit your BOI report and keep in touch to ensure you keep it updated.

Explore Our Services Beyond BOI Reporting

Harbor Compliance offers an array of services that help you stay on top of all your regulatory obligations. Whether your organization has only gotten off the ground or been active for years, we can support it throughout its lifecycle by completing the following tasks in your name:

• Reserving a name
• Obtaining and EIN
• Managing DBAs
• Filing initial and annual reports
• Amending your formation documents
• Completing the withdrawal process

You can also appoint us as your registered agent to let us accept legal and government notices on your behalf, ensuring they don't go unnoticed. Our Change of Agent Service lets you partner with us even if you already have an agent, as we can complete the change without any effort needed on your part.

If you need a general business license or an industry-specific one (construction, engineering, etc.), we can help you obtain and manage them. We can also obtain various other documents on your behalf, such as:

• Certificate of good standing or authority
• Certified copies
• Articles of reinstatement

Besides retrieving your documents, we can submit important filings to the secretary of state or other governing bodies through our Drop-Off Filing Service. We deliver your documents in person, which gives them priority over those sent by mail or online.

Our additional area of expertise is nonprofit formation. We can complete the incorporation or charitable registration process from start to finish and secure your 501(c) tax exemption to help you start raising funds quickly.

BOI Reporting FAQs

Below, you'll find answers to some of the commonly asked questions about BOI reporting. If you need additional guidance, visit FinCEN's FAQ page or the Harbor Compliance Information Center.

Enjoy Stress-Free BOI Reporting With Harbor Compliance

Like other regulatory requirements, BOI reporting should be handled by experts. Order our BOI Reporting Service today, and we'll make sure your report is submitted and updated timely without much action needed on your part.

If you need help staying on top of your other obligations, you can also take the following steps:

• Get a free Harbor Compliance Score™ to check for any unresolved regulatory matters.
• Inquire about our additional services for a custom set of solutions.

You can also schedule a demonstration of our robust compliance platform to discover the many ways it can help you meet your obligations without hassle.