Beneficial Ownership Information (BOI) Requirements for CA Businesses

Amy Hsiao

August 26, 2025

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What is Beneficial Ownership Information (BOI), and Why Should CA Business Owners Care?

In recent years, there’s been a big push at both the federal and state level to make business ownership more transparent. If you own a California LLC, small corporation, or manage a trust, you’ve probably heard about the new Beneficial Ownership Information (BOI) requirements.Let’s break it down simply: BOI asks companies to report who really owns, controls, or benefits from a business (not just who’s listed on the paperwork). The aim is to shine a light on anonymous companies that could be used for money laundering or tax evasion. But for honest business owners, it’s mostly about filling out new forms and staying on top of deadlines.This guide will walk you through what you need to report in 2025, how the federal Corporate Transparency Act (CTA) affects California business owners, and what changes might be coming from the state of California itself.

Who Needs to File? (And Who's Off the Hook?)

The vast majority of California LLCs, small corporations, and business entities held in trusts may need to file under the new rules. Basically, if you’re a small privately-owned business, you probably need to report.You likely need to file if:

You own or control an LLC, corporation, or a business entity held in a trust
Your business is registered with the California Secretary of State or operates in California

You probably do NOT need to file if:

Your company is publicly traded
You’re a large company meeting certain employee/revenue thresholds (typically over 20 U.S.-based employees and $5M annual gross receipts)
Nonprofits (although always double-check—there are exceptions!)

If you’re unsure, check the FinCEN “Small Entity Compliance Guide”, or reach out to a trusted legal professional.

Federal BOI Reporting: Corporate Transparency Act at a Glance

Let’s start with what’s already in force. The Corporate Transparency Act (CTA) rolled out nationwide reporting through FinCEN, aiming to make it harder for bad actors to hide behind shell companies. What does that mean for you?

Key Deadlines You Can’t Miss

If your business was created before January 1, 2024:You must file your initial BOI report with FinCEN by January 1, 2025.
If your business is created in 2024:You have 90 calendar days from the date your company is registered with the California Secretary of State to file your BOI report.
If your business is created on or after January 1, 2025:You have 30 calendar days from registration to file.
🕒 Ongoing compliance: You must file an updated report within 30 days of any change to your company or beneficial owner’s information (e.g., change in ownership, address, or ID number).

FinCEN: Beneficial Ownership Reporting DeadlinesThis is not a “set it and forget it”—you’ll have to update your BOI any time your company or beneficial owners’ info changes.

What Exactly Do I Need to Report?

Your BOI report covers details about the company and each one of its “beneficial owners.” That means anyone owning at least 25% of the company OR who has significant control (think: the “decision makers”).Company Info Required:

Legal names (including any “DBA” or trade names)
Taxpayer Identification Number (TIN or EIN)
Jurisdiction of formation
Street address

Beneficial Owner Info Required:

Full legal name
Date of birth
Current residential or business address
ID number (from a current U.S. passport, driver’s license, or similar official ID)
A photo/scan of the actual ID

“Company Applicant” Info:If your business was registered after Jan 1, 2025, you’ll also need to report who filed the initial documents to create/register your company.Pro tip: For a detailed checklist (in English or Chinese), visit our Estate Planning Resources.

What Counts as a “Beneficial Owner,” Anyway?

Not everyone who touches your business must be reported. The rules focus on key people:A “beneficial owner” is:

Anyone who owns 25%+ of your company, or
Anyone who exercises “substantial control” (e.g., CEO, President, Treasurer, or a managing partner)

Some people are typically excluded:

Employees without significant control or ownership
Creditors (unless they also meet ownership/control thresholds)
Minor children (but report their parent/guardian instead)

How to File Your BOI Report

You file directly with FinCEN, the U.S. Treasury’s Financial Crimes Enforcement Network. Good news: There’s no filing fee, and it’s all online.

Head to the FinCEN BOI E-Filing System:https://boiefiling.fincen.gov/
Gather your documents:(Company info, ownership breakdowns, and ID documents/scans for each owner/applicant)
Complete the online form.You’ll get confirmation once it’s accepted.

Want help? Law firms (like ours) and accounting professionals can handle the BOI filing process for you—and give extra peace of mind that it’s done right.

Ongoing Compliance: Changes, Updates, and Amendments

Filing once is just the beginning. If anything changes—like you move, a new owner is added, or someone’s name changes—you must file an updated BOI report within 30 days.Examples of when to update:

Add or remove a business owner
Update ownership percentages
Change addresses or key personal details
New IDs issued (e.g., renewed passport, driver’s license)

Missing an update or getting it wrong has real consequences—so set calendar reminders and keep those business records up-to-date!

Penalties for Missing the Mark

FinCEN isn’t playing around. Missing a deadline or filing false/incorrect information could mean:

Civil fines: up to $500 per day the error continues
Criminal penalties: up to $10,000 and/or up to 2 years in prison

Even accidental mistakes can bring heat. Best to err on the side of caution and fix issues quickly if spotted.

California-Specific Guidance: Is More Coming in 2026?

California mirrors many federal transparency rules, but proposed SB 1201 (Senate Bill 1201) would go further.If passed, SB 1201 will require all California LLCs and corporations to submit BOI reports directly to the Secretary of State, starting January 1, 2026.Key differences from federal BOI:

Reports are biannual
Initial report due within 90 days of formation/registration
As of August 2025, SB 1201 has passed the CA Senate but is not law yet

For now, focus on federal BOI filings, but be alert for dual reporting beginning in 2026 if enacted.

BOI for Trusts: What If My Business Is in a Trust?

If your LLC or corporation is held in trust, the trust itself does not file a BOI report. People connected to the trust may still need to be reported as beneficial owners.

Trustee: Reportable if they exercise substantial control or own 25%+
Grantor: May be reportable if they retain control or have revocation powers
Beneficiaries: Generally reportable only if they directly access/control assets

Important: If a trust owns 25%+ or the trustee manages the business, it’s essential to carefully determine who meets the FinCEN definition of "beneficial owner." Consult a qualified attorney or tax professional.Note on Trusts: Most estate planning trusts (like revocable or irrevocable living trusts) do not need to file BOI reports themselves. If such a trust owns a reporting company (such as an LLC), individuals involved—trustee, grantor, beneficiary—may be classified as beneficial owners for the company's BOI filing.

Resources in English & Chinese

We want to make compliance approachable for everyone!

Still have questions? Reach out to our team for one-on-one help, bilingual support, or curated checklists.

Wrap-Up & Next Steps (Checklist)

Ready to tackle your BOI requirements? Here’s a handy checklist:

Determine if your company is required to file BOI
Gather info on all beneficial owners & company applicants
File your initial BOI with FinCEN (check your entity’s due date!)
Set reminders for updating BOI if anything changes
Keep an eye on California’s SB 1201 news for future state filings
Consult professionals for help with tricky scenarios, especially trusts or cross-border ownership

Good compliance today means fewer headaches and legal risks tomorrow. Need help along the way? Nikko Guevarra’s compassionate team is just a click away.Looking for this article in Chinese or have specific language needs? Let us know! Our team is proud to help all California small business owners and families build a legally secure future.Need more info or want a step-by-step walkthrough? Check our resources or contact us directly!