FinCEN BOI FAQ E.1
Who is a company applicant of a reporting company?
Cite as FinCEN Beneficial Ownership Information FAQ E.1 (Company Applicant)
Only reporting companies created or registered
on or after
January 1, 2024, will need to report their company applicants.
A company that must report its company applicants will have only up to two individuals who could qualify as company applicants:
The individual who directly files the document that creates or registers the company; and
If more than one person is involved in the filing, the individual who is primarily responsible for directing or controlling the filing.
The following flowchart can help identify the company applicant.
In addition, Chapter 3.2, “Who is a company applicant of my company?” of FinCEN’s
Small Entity Compliance Guide
includes additional information to help identify company applicants.