Week 3 of our CTA Update Series – Due Dates and Penalties
Initial Report Due Dates for Beneficial Ownership Information (BOI) Reporting:
– Existing Entities (created/registered by 12/31/2023) – must file by 1/1/25.
– New entities (created/register in 2024) – must file within 90 days.
– New entities (created/registered after 12/31/2024) – must file within 30 days.
Updates to BOI Reporting:
– You must file an updated BOI report if there are any changes to the information
reported on the initial BOI report about your company or the beneficial owner(s).
An updated report must be filed no later than 30 days after the change occurred.
Examples of when an updated BOI report would be required:
– Any change to the previously reported information for the reporting company.
For example, when there is a change to the business name.
– Any change to a beneficial owner’s name, address, or unique identifying number.
In addition, an image of the new identifying document would also need to be
submitted if the document has a change of name, address, or identifying number.
– There is a change in the beneficial owner(s). Examples include a change in
ownership interest that meets the 25 percent ownership threshold or hiring of a
new CEO.
– The reporting company qualifies for exempt status after filing the initial BOI
report.
Penalties
Penalties for willfully not complying with the BOI reporting requirement can result in criminal
and civil penalties of $500 per day and up to $10,000 with up to two years of jail time. For more
information about the CTA, visit www.aicpa-cima.com/boi.
In reference to late filing of updated BOI reports, you may avoid penalties if you correct the
mistake and/or omission within 90 days of the deadline for the original report
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