File Beneficial Ownership Information Report (FinCEN BOIR)

Skill: Convert beneficial-ownership data into a FinCEN BOI report

Region: United States Category: Government — FinCEN Does: Takes a reporting company's beneficial-ownership data and assembles the Beneficial Ownership Information Report (BOIR) filed through the FinCEN BOI E-Filing System, identifying the company, its beneficial owners, and (where applicable) company applicants. Spec: FinCEN Beneficial Ownership Information (BOI) — BOIR E-Filing (current interim final rule)

LOW CONFIDENCE — verify current status before any filing. The Corporate Transparency Act's BOI regime changed materially: a March 2025 interim final rule EXEMPTS U.S.-formed entities (domestic reporting companies) and U.S. persons from BOI reporting. The obligation now applies only to foreign reporting companies — entities formed abroad and registered to do business in a U.S. state/tribal jurisdiction — and even that remains subject to ongoing litigation and possible further rulemaking. Do not rely on this skill to determine whether a given entity must file. Confirm current obligations, deadlines, and exemptions against current FinCEN guidance (fincen.gov) and counsel before use. Element/field names below follow the form of the BOIR, not a verbatim published schema.

When this applies

• The entity is a foreign reporting company — formed under the law of a foreign country and registered to do business in a U.S. state or tribal jurisdiction by filing with a secretary of state or equivalent — and no exemption applies.
• U.S.-formed (domestic) entities are exempt under the March 2025 interim final rule and generally should not file — confirm status before relying on this.
• A previously filed BOIR needs an updated or corrected report (e.g., a change in beneficial owners, or to fix an error).
• The 23 statutory exemptions (large operating company, regulated entities, etc.) do not apply.

Structure (beneficial-ownership data → BOIR)

BOIR
  Filing type: initial / update / correction / newly exempt
  Reporting company
    legal name + any trade/DBA names
    foreign jurisdiction of formation
    U.S. registration jurisdiction(s)
    TIN (EIN/ITIN) or foreign tax ID + issuing country
    current U.S. address
  Company applicant(s)        (only if registered on/after 2024-01-01)
    name, DOB, address, identifying document + image (passport/license)
  Beneficial owner(s)         (each individual with >=25% ownership OR
                               substantial control)
    name, DOB, residential address
    identifying document type, number, issuing jurisdiction + image
  (alternative) FinCEN ID in place of an individual's repeated details

Data rules

• A beneficial owner is any individual who exercises substantial control or owns/controls at least 25% of the ownership interests; both tests apply.
• Company applicants are reported only for foreign companies first registered on or after January 1, 2024 — companies registered earlier omit them.
• Each individual requires a current identifying document (passport, U.S. state license/ID, or foreign passport) with the document number, issuing jurisdiction, and an image upload.
• A FinCEN Identifier may be supplied in place of an individual's full details once that person has obtained one.
• Updates must be filed within 30 days of a change to reported company or beneficial-owner information; corrections within 30 days of becoming aware of an inaccuracy.
• Confirm whether the entity is exempt (domestic entities under the 2025 rule, plus the 23 statutory exemptions) before filing — an exempt entity should not submit a report.

Worked example (outline)

Filing type: initial
Reporting company:
  legal name = GLOBALCO LTD
  formation jurisdiction = United Kingdom (foreign)
  U.S. registration = Delaware
  TIN = foreign tax ID (issuing country GB) / EIN if assigned
  U.S. address = 100 Market St, Wilmington DE 19801
Company applicant: (registered after 2024-01-01) Jane Roe, DOB, address,
  UK passport #, image
Beneficial owner: John Smith — 40% ownership + CEO (substantial control)
  DOB, residential address, US passport #, image

Submitted through the FinCEN BOI E-Filing System as a BOIR — only if the foreign-company obligation applies and no exemption is available.

Validation checklist

• Current BOI obligation verified — under the March 2025 interim final rule, U.S.-formed entities are exempt; this applies only to foreign reporting companies, and the rule is subject to litigation (LOW confidence)
• Entity is a foreign reporting company registered in a U.S. jurisdiction and not exempt (23 statutory exemptions checked)
• Filing type set (initial / update / correction); prior report referenced for updates/corrections
• Reporting company: legal + trade names, formation jurisdiction, U.S. registration, TIN, U.S. address
• Beneficial owners identified via both tests (>=25% ownership and substantial control)
• Company applicants included only if first registered on/after 2024-01-01
• Each individual: name, DOB, address, ID document + number + issuing jurisdiction + image (or FinCEN ID)
• Update/correction filed within 30 days; submitted via FinCEN BOI E-Filing System

Last updated: 2026-06-04 — LOW confidence: the March 2025 interim final rule exempts U.S.-formed entities and the foreign-company obligation remains subject to litigation and possible rulemaking. Confirm whether any filing obligation exists, plus element names, the current BOIR schema, exemptions, and deadlines, against current FinCEN BOI E-Filing guidance (fincen.gov) and counsel before use.