Typically, a company that loses its exempt status must file a BOI report with FinCEN within 30 calendar days after losing its exemption. However, a reporting company created or registered before January 1, 2024, has until January 1, 2025, to file its initial BOI report.
FinCEN has determined that previously exempt entities existing before 2024 and losing their exempt status in 2024 will benefit from the longer of the two following timeframes:
- The remaining days in the one-year filing period for existing companies.
- The 30-calendar-day period after losing exempt status.
For example:
- If a reporting company loses its exemption on February 1, 2024, it has until January 1, 2025, to file its initial BOI report.
- If the company loses its exemption on December 15, 2024, it has until January 14, 2025, to file its initial BOI report.