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The Corporate Transparency Act (CTA) mandates that reporting companies must report their beneficial ownership information (BOI) to the Financial Crimes Enforcement Network (FinCEN) to promote transparency and combat illicit activities. To comply with these regulations, entities must first file an initial BOI Report by their first due date. However, while some companies may very rarely need to file another report, there will be many that will file the different types of BOI reports at various stages. Here, we explain the four types of BOI reports required under the CTA: Initial, Update, Correction, and Newly Exempt Entity.
1. Initial Report
The initial report is the first BOI report that each entity must file by their respective due date. This report sets the foundation for compliance and will be submitted only once. The due dates for filing the initial report are as follows:
- Entities formed before January 1, 2024 have until January 1, 2025, to file their initial report.
- Entities formed in 2024 have 90 days from the confirmation of formation to file their initial report.
- Entities formed in 2025 and beyond must file their initial report within 30 days of formation.
2. Updated Report
An updated report is required when any previously filed information becomes outdated or incorrect. Entities must file an updated report within 30 days of the change in information. Situations that may trigger the need for an updated report include changes in beneficial ownership, changes in the entity’s address, or changes in the personal details of beneficial owners. Some entities may not file an updated report for years after filing their initial report, others may need to file just after a few months. There is no limit to how many updated BOI Reports can be filed.
3. Corrected Report
A corrected report is necessary when an entity realizes that the information previously filed was inaccurate. 
This report must be filed within 30 days of discovering the mistake. The corrected report ensures that the BOI database remains accurate and reliable. Common errors that might necessitate a corrected report include typographical errors, incorrect DOBs, incorrect residential addresses, or omitted beneficial owners.
4. Newly Exempt Entity Report
The newly exempt entity report is for entities that have already filed an initial BOI Report but subsequently meet the criteria for an exemption from reporting. This applies to entities that fall into one of the 23 categories of exempt entities outlined by the CTA. Once an entity qualifies for exemption, it has 30 days to file a newly exempt entity report. It is essential to monitor the exemption status continually, as changes in the entity’s status might require re-filing under the CTA.
Maintaining Transparency
Compliance with the Corporate Transparency Act requires entities to understand and accurately file the appropriate BOI reports. The initial report sets the compliance baseline, while updated and corrected reports ensure ongoing accuracy. The newly exempt entity report acknowledges changes in status that affect reporting obligations. By adhering to these requirements and maintaining vigilance over any changes in information or status, entities can ensure compliance and contribute to the broader goals of transparency and integrity in corporate governance.
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