The Financial Crimes Enforcement Network, or FinCEN, began accepting beneficial ownership information reports on January 1, 2024. Filing was free, but covered companies needed personal identification records for the people who ultimately owned or controlled them. The office task extended beyond submitting a company’s name and address: first reports had deadlines, and information could need updating afterward. [S1]

The first deadline depended on when a reporting company was created or registered to do business in the United States. Those created or registered before January 1, 2024, had until January 1, 2025. Companies created or registered during 2024 had 90 calendar days from the earlier of actual notice or public notice that creation or registration was effective. That longer window was temporary: the November 2023 amendment retained a 30-day initial filing period for companies created or registered from January 1, 2025. These were the deadlines at the January 2024 launch, not current filing guidance. [S1][S2][S4]

For each beneficial owner, FinCEN generally required a name, birth date and address, plus an unexpired identification document’s number and issuer. Accepted documents included a U.S. driver’s license, a U.S. passport, or identification issued by a state, local government or Indian tribe; the state category included U.S. territories and possessions. An unexpired foreign passport was an option only if none of those other documents existed. The filing also required an image of the document. [S1]

The business also had to supply its own information, including its name or names and address. Reporting companies created on or after January 1, 2024, had an additional task: providing information about company applicants, including the individuals who filed the creation or registration document. An ownership list alone would not supply all of those records. [S1][S4]

FinCEN said beneficial ownership reporting was not an annual requirement, but reports still needed updating or correction when appropriate. Under the framework then in effect, changes in beneficial ownership information required updates within 30 days. The November amendment gave new 2024 companies more time to file their first reports; it expressly declined to extend the deadlines for updates or corrections. A business could not carry its initial 90-day window over to those later filings. [S1][S3][S4]

Source documents

  1. U.S. Beneficial Ownership Information Registry Now Accepting Reportshttps://www.fincen.gov/news/news-releases/us-beneficial-ownership-information-registry-now-accepting-reports
  2. FinCEN Extends Deadline for Companies Created or Registered in 2024 to File Beneficial Ownership Information Reportshttps://www.fincen.gov/news/news-releases/fincen-extends-deadline-companies-created-or-registered-2024-file-beneficial
  3. FinCEN Issues Final Rule for Beneficial Ownership Reporting to Support Law Enforcement Efforts, Counter Illicit Finance, and Increase Transparencyhttps://www.fincen.gov/news/news-releases/fincen-issues-final-rule-beneficial-ownership-reporting-support-law-enforcement
  4. Beneficial Ownership Information Reporting Deadline Extension for Reporting Companies Created or Registered in 2024https://www.govinfo.gov/content/pkg/FR-2023-11-30/html/2023-26399.htm