Data Governance Briefing — January 1, 2025
Corporate Transparency Act reporting hits a hard January 1, 2025 deadline for legacy entities while new companies must submit beneficial ownership information to FinCEN within 30 days of formation.
Executive briefing: The U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN) sets January 1, 2025 as the deadline for reporting companies created before 2024 to file initial beneficial ownership information (BOI) reports under the Corporate Transparency Act. Beginning the same day, newly formed entities have only 30 days after creation or registration to submit BOI filings through the BOI e-filing system.
Key regulatory signals
- Legacy entity deadline. Domestic and foreign reporting companies in existence before January 1, 2024 must have complete BOI reports on file by January 1, 2025 covering beneficial owners and company applicants where required.
- Accelerated reporting window. Entities created or registered on or after January 1, 2025 must file within 30 calendar days; those formed during 2024 retain the temporary 90-day window through year-end.
- Change management. Any subsequent updates or corrections to BOI data must be filed within 30 days, requiring sustainable monitoring of ownership and control changes.
Operational priorities
- Inventory subsidiaries. Reconcile legal entity management systems against FinCEN’s reporting company definitions to confirm which domestic and foreign subsidiaries require BOI submissions.
- Data quality controls. Centralize collection of beneficial owner identity evidence (passport, driver’s license, FinCEN identifier) and validate records for formatting and expiration to avoid rejection.
- Workflow automation. Configure entity management platforms or RPA bots to trigger BOI filing tasks immediately upon new entity formation or ownership changes.
Enablement moves
- Brief treasury, legal, and tax teams on the shortened 30-day window and establish escalation paths for hard-to-contact beneficial owners.
- Document cross-border data transfer considerations when storing BOI artifacts to align with GDPR, CPRA, and other privacy regimes.
Sources
- FinCEN Beneficial Ownership Information Reporting requirements
- Federal Register: Beneficial Ownership Information Reporting Requirements
Zeph Tech automates CTA compliance by integrating entity management, identity proofing, and BOI submission evidence into enterprise governance workflows.