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VSCPA supports deadline extension and expansion in beneficial ownership reporting requirements

November 9, 2023

The VSCPA has joined the American Institute of CPAs (AICPA) and dozens of other state CPA societies to ask the Financial Crimes Enforcement Network (FinCEN) to extend and expand the deadline for beneficial ownership information (BOI) reporting requirements, specifically for reporting companies created or registered in 2024. 

Effective Jan. 1, 2024, existing companies, companies created or registered before Jan. 1, 2024, will have one year — through Jan. 1, 2025 — to file their initial BOI reports. New companies, companies created or registered on or after Jan. 1, 2024, will have 30 days to file their initial BOI reports. If there are inaccuracies in the initial BOI report filed or companies have a change in information, such as a change in residential address or percentage of ownership, they will have 30 days to report changes or correct the inaccuracies. 

The BOI reporting requirement is an anti-money laundering initiative enacted through the Corporate Transparency Act (CTA) in 2021, which mandates that BOI information is reported to FinCEN.

In a comment letter sent Oct. 30, 2023, the CPA profession specifically recommends FinCEN extend the deadline from the proposed 90 days to one year and expand the applicability of the deadline to include not only new entities created in 2024 but ALL entities created thereafter — as well as entities making updates or corrections to their original filings.

Lack of awareness is highlighted in the letter, citing that most businesses are not familiar with the new BOI regulation, despite the campaigns put in place to inform them. The time and financial burdens on small businesses were also mentioned as a potential result of not instituting the recommended changes. The comment letter also hopes to avoid the steep taxpayer penalties that could accompany unawareness of the new reporting requirements.

Here are more resources related to the BOI reporting requirement, as well as the VSCPA’s advocacy on the issue: