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CTA Compliance Checklist

Corporate Transparency Act checklist for small businesses

CTA Compliance Checklist

Corporate Transparency Act (CTA) & BOI Reporting Update

Important Update for U.S. Business Owners

The Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA) have changed significantly.

U.S.-formed businesses are currently exempt from BOI reporting requirements.

In March 2025, the Financial Crimes Enforcement Network (FinCEN) issued an interim final rule that removed BOI reporting requirements for companies created in the United States and their beneficial owners.

This means that most U.S.-formed LLCs, corporations, and other domestic business entities are no longer required to file a Beneficial Ownership Information report with FinCEN.

Who May Still Be Required to File?

BOI reporting requirements now generally apply only to certain entities that:

  • Were formed under the laws of a foreign country; and
  • Have registered to do business in a U.S. state or Tribal jurisdiction; and
  • Do not otherwise qualify for an exemption.

Foreign entities that become registered to do business in the United States on or after March 26, 2025, generally have 30 calendar days after receiving notice that their registration is effective to file an initial BOI report.

Additionally, qualifying foreign reporting companies are not required to report U.S. persons as beneficial owners, and U.S. persons are not required to provide their beneficial ownership information for these reports.

What Does This Mean for Your Business?

If your LLC or corporation was created in the United States, you are currently exempt from the federal BOI reporting requirement.

If your company was formed outside the United States and registered to conduct business in the U.S., additional review may be necessary to determine whether a BOI filing is required.

Stay Informed

Corporate Transparency Act requirements have changed substantially since the original rules took effect on January 1, 2024. Business owners should be cautious when relying on older websites, emails, compliance notices, or filing solicitations stating that all LLCs and corporations are required to submit BOI reports.

BizAccountants continues to monitor changes to federal business compliance requirements and can help business owners determine which filing requirements apply to their companies.

Last Updated: August 2026

This information is provided for general informational purposes and should not be considered legal advice.

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Step 1: Determine the Applicability for BOI Report Filing

  • Assess your business’s entity type (LLC, corporation, limited partnership, etc.) to ascertain the filing requirement.
  • Understand that LLCs and corporations are generally obligated to file a BOI report, barring specific exemptions.
  • For entities other than LLCs or corporations, evaluate whether you need to file a BOI report based on FinCEN’s definitions and guidance. Seek legal counsel if necessary.

Step 2: Evaluate Potential Exemptions

  • Investigate if your business qualifies as a “large operating company” or an “inactive entity” for exemption.
  • Review other possible exemptions and consider professional legal advice for clarity.

Step 3: Preparations for Filing a BOI Report

  • Identify the beneficial owners of your business.
  • If the criteria for beneficial ownership are unclear, seek legal advice.
  • Notify each beneficial owner about the CTA’s requirement to report their personal data to FinCEN.
  • Choose between obtaining the information directly from beneficial owners or applying for a FinCEN Identifier.
  • Gather and update the necessary information for the initial BOI report.

Step 4: Establish an Ongoing Information Update Procedure

  • Ensure the data is current for the initial filing and for subsequent required updates.
  • Consider implementing an entity management system for efficiency.
  • Prioritize secure storage of personal information.

Step 5: Plan the Submission of Your Initial BOI Report

  • Decide on the timing of your filing within the one-year window starting January 1, 2024.
  • Determine whether to file independently or seek assistance from a third-party service provider.

Step 6: Duplicate the Process for Each Business Entity You Own

  • Replicate steps 1 through 5 for each business entity under your ownership to ensure comprehensive compliance.

Additional Considerations for Enhanced Compliance Strategy

  • Entity Evaluation: Assess the necessity of maintaining existing entities. Contemplate the dissolution of entities that are redundant or inactive to streamline your corporate structure.
  • Strategic Entity Formation: If you are contemplating the establishment of a new entity, evaluate the benefits of forming it prior to January 1, 2024. This timing would categorize it as an existing entity under the new law, potentially allowing for an extended timeframe for BOI report filing.
  • Governance Documentation Update: Review and, if necessary, revise your governing documents, such as operating agreements or shareholder agreements, to incorporate provisions about the obligations of beneficial owners in providing personal information as required under the CTA.
 

Preparation for Beneficial Ownership Information Reporting:

The effective date for BOI reporting under the Corporate Transparency Act is fast approaching. Utilize this comprehensive checklist as a guide to ensure your business is fully prepared and compliant with the new regulatory requirements.

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