If there is any change to the required information about a reporting company or its beneficial owners (including to their personal information) included in a filed report, a reporting company must report the updated information to FinCEN within the later of (a) 30 days after the date on which the change occurred, and (b) March 21, 2025. The same 30-day timeline applies to changes in information submitted by an individual to obtain a FinCEN identifier. However, there is no requirement to report changes regarding a company applicant to FinCEN.
If an inaccuracy is identified in a filed report, the company must correct it no later than 30 days after the date the company became aware of the inaccuracy or had reason to know of it. This includes any inaccuracy in the required information provided about the company, its beneficial owners, or its company applicants. The same 30-day timeline applies to inaccuracies in information submitted by an individual in order to obtain a FinCEN identifier. Note: There are no penalties for filing an inaccurate BOI report provided it is corrected within 90 calendar days of when it was filed.
However, on February 27, 2025, FinCEN announced that by March 21, 2025, it plans to issue an interim final rule that will extend the current BOI reporting deadlines under the Corporate Transparency Act. Until the new rule is in effect and its deadlines have passed, FinCEN indicated that it will not impose fines or penalties on companies for updating BOI reports.