Does a Reporting Company Created in 2024 or Later Need to File an Initial BOIR if It Ceases to Exist Before the Report Is Due?

Yes, Reporting Companies created or registered in 2024 are required to report their beneficial ownership information to FinCEN within 90 days of receiving notice of creation or registration. Companies created or registered in 2025 or later must report within 30 days of receiving notice.

These reporting requirements remain in effect even if the company winds up its affairs and ceases to exist before the initial BOIR is due. If a Reporting Company files its initial BOIR and subsequently ceases to exist, it is not required to submit an additional report to FinCEN to indicate that it has dissolved.