EIN and Beneficial Ownership (BOI) reporting: what changed for 2026

Getting an EIN in 2026 is still the same 10-minute IRS process it has been for decades. What has changed for new US business entities is what comes after the EIN: the Beneficial Ownership Information (BOI) reporting framework introduced by the Corporate Transparency Act (CTA), enforced by the Financial Crimes Enforcement Network (FinCEN). The interaction between the EIN application and BOI reporting is where most founders get confused — and where a missed filing can create real problems.

This is what BOI reporting is, how it relates to your EIN and business credit setup, and how Sterling's EIN wizard sequences the two so nothing falls through.

What is Beneficial Ownership Information reporting

The Corporate Transparency Act (CTA) — passed in 2021 as part of the National Defense Authorization Act — requires certain US business entities to file Beneficial Ownership Information with FinCEN. The reporting captures who ultimately owns or controls the entity, with the stated purpose of making it harder to hide ownership behind shell companies for money laundering, sanctions evasion, and tax evasion.

A BOI report typically discloses, for each beneficial owner:

• Full legal name
• Date of birth
• Current residential address
• A unique identifier (typically a driver's license or passport number)
• An image of the identifying document

A beneficial owner is generally defined as any individual who either (a) owns 25% or more of the entity, or (b) exercises substantial control over it — regardless of ownership percentage. Company applicants (the individual who filed the entity with the state) may also be required to file for entities formed after the CTA effective date.

Who is generally required to file

The CTA divides entities into two broad categories:

• Reporting companies: corporations, LLCs, and similar entities formed by filing a document with a US Secretary of State (or equivalent). Also includes foreign entities registered to do business in a US state.
• Exempt entities: 23 categories including publicly traded companies, most nonprofits, banks and credit unions, insurance companies, registered investment advisors, and — importantly for small businesses — the large operating company exemption for entities with more than 20 full-time US employees, more than $5 million in prior-year US gross receipts, and a physical US operating presence.

Most Sterling users — pre-revenue LLCs and small S-corps at the start of business credit building — are "reporting companies" not covered by any exemption. The 20-employee/$5M-revenue threshold specifically carves out established businesses, not startups.

EIN and BOI are separate filings

Every new US business owner asks this: does the IRS EIN application feed BOI data to FinCEN? No. The EIN application (Form SS-4) and the BOI report are separate filings with separate agencies. Getting an EIN does not satisfy any BOI requirement. Filing a BOI report does not eliminate any IRS obligation.

The typical sequence for a new entity

1. 1File the entity with the state. LLC Articles of Organization or Corporation Certificate of Incorporation. Wait for confirmation from the Secretary of State — you cannot apply for an EIN before the entity legally exists.
2. 2Apply for an EIN with the IRS. Same-session issuance online through IRS.gov if the responsible party has an SSN or ITIN. Save the CP 575 confirmation notice — it cannot be reissued.
3. 3Confirm current BOI obligation on FinCEN's site.Because the rules have been subject to litigation and revision, do not rely on last year's advice or a template checklist. Check the current status at fincen.gov/boi before assuming you do or do not need to file.
4. 4File the BOI report if required.Filing is free through FinCEN's BOI E-Filing System at boiefiling.fincen.gov. There is no fee for the report itself — any service charging you a fee for BOI filing is reselling a free government service.
5. 5Set BOI update tracking.If required to file initially, you are also required to file updates within 30 days of any change to a beneficial owner's information — address change, name change, expired driver's license replacement. This is the compliance obligation most founders miss because it does not recur on a fixed schedule.

What BOI reporting does not do

• It does not create public disclosure.BOI reports go to FinCEN's secure registry and are not searchable by the public, press, competitors, or credit bureaus. Only authorized federal, state, and (in narrow circumstances) foreign law enforcement can access the data.
• It does not appear on your business credit report.D&B, Experian Business, and Equifax do not receive FinCEN data. BOI filing has no direct effect on Paydex, Intelliscore, or SBDS scores.
• It does not replace state entity filings or IRS filings. Annual state reports, franchise tax filings, and IRS tax returns remain independently required.
• It does not gate business credit or lender applications. Vendors and lenders do not typically ask for BOI confirmation. But failure to file when required is a separate compliance risk — civil penalties can reach $500 per day for continuing violations under the current statutory framework.

How Sterling handles BOI in the setup flow

Sterling's EIN wizard concludes the EIN issuance path with a BOI awareness step — a checkpoint that reminds new entity owners BOI reporting is a separate, likely-applicable obligation, and links directly to the current FinCEN filing site and rule status page. Sterling does not file the BOI report on your behalf — that requires personal identification documents Sterling does not collect and legal judgment we are not licensed to make. Sterling makes sure it is not overlooked.

The Compliance Center on Builder and Accelerate plans then tracks BOI update obligations: if you have flagged that you filed BOI, Sterling asks periodically whether any beneficial owner information has changed (address, ID document expiration, ownership change), so the 30-day update window does not silently elapse.

The EIN still comes first

None of the BOI framework changes the value of getting your EIN correctly and quickly. Business banking, Net-30 vendor applications, DUNS registration, and every downstream business credit action gates on the EIN. Get the EIN issued first, save the CP 575 immediately, and then treat BOI as the next distinct step — not as part of the EIN filing itself.

For the field-by-field walkthrough of the EIN application itself, see How to get an EIN in 2026. For the full business setup sequence, see How to build business credit fast: the 90-day plan.