![EXPLAINED: FinCEN BOI Filing Requirement for Churches [2025]](https://solasites.com/media/BOI-filing-requirement-for-churches.jpeg)
EXPLAINED: FinCEN BOI Filing Requirement for Churches [2025]
Whether you’re a pastor, church leader, or simply seeking to shepherd your congregation wisely, you may have heard about the new FinCEN Beneficial Ownership Information (BOI) filing requirement. As stewards of God’s resources and the ministries entrusted to us, it’s important to understand what this regulation means and whether it applies to your church. Our calling is not only to serve faithfully but also to handle all things—including financial and legal matters—above reproach (2 Corinthians 8:21). Let’s walk through this together.
1. What Is the FinCEN BOI Filing Requirement for 2025?
The Financial Crimes Enforcement Network (FinCEN), under the Corporate Transparency Act (CTA), is requiring certain entities to report their beneficial ownership information (BOI). This regulation, effective January 1, 2025, is part of an effort to combat financial crimes such as money laundering and tax evasion. While these may seem like distant concerns for the church, we are reminded in Romans 13:1-7 of our duty to submit to governing authorities as long as it does not compromise our allegiance to Christ.
Under this regulation, many organizations will need to file a Beneficial Ownership Information Report (BOIR), providing details such as:
- Full legal name
- Date of birth
- Residential or business address
- A unique identifying number (e.g., a passport or driver’s license number)
The goal is to create greater transparency in financial dealings. Non-compliance can lead to penalties, including fines and potential criminal charges, underscoring the importance of acting with integrity in these matters.
2. Who Needs to File?
The filing requirement applies broadly to domestic and foreign entities registered to do business in the United States, including:
- Corporations
- Limited liability companies (LLCs)
- Other entities created by filing documents with state or tribal authorities
However, certain organizations are exempt, including publicly traded companies, banks, and nonprofits that meet specific criteria.
3. Where Do You File?
For those who are required to file, submissions can be made through an online portal provided by FinCEN. Details and resources are available at boiefiling.fincen.gov.
4. Do Churches Need to File?
The short answer for most churches is no, but let’s consider why. Churches and other religious organizations are generally exempt from the BOI filing requirements. Here’s why:
- Nonprofit Exemption: Most churches qualify as tax-exempt organizations under 26 U.S.C. § 501(c)(3). This exemption reflects their mission to serve others and advance the gospel, not to generate profit or accumulate wealth.
- No Beneficial Owners: Unlike for-profit corporations, churches do not have “owners” or “beneficial owners.” The church belongs to Christ (Ephesians 1:22-23), and its governance is typically carried out by boards or leadership teams, which fall outside the scope of this regulation.
- IRS Oversight: Churches are already subject to oversight through the IRS and other reporting obligations, such as filing an annual Form 990 in some cases (though churches themselves are often exempt from filing).
However, there are exceptions. If a church operates a for-profit subsidiary (such as a bookstore, coffee shop, or event venue) that is registered as a separate legal entity, that entity may need to file. This is an area where wisdom and discernment are needed, as leaders bear the responsibility of ensuring compliance while remaining focused on ministry priorities.
5. Why Are Churches Exempt?
The exemption reflects a recognition of the unique nature of churches and their mission. Churches exist not for personal gain, but to glorify God by proclaiming His truth and serving others. They are already under the watchful eye of public accountability, whether through their testimony in the community or their adherence to biblical standards of stewardship (1 Timothy 3:2-7).
Still, this exemption is not an excuse for carelessness. As Paul reminds us in Colossians 3:23-24, “Whatever you do, work heartily, as for the Lord and not for men.” Churches should take these requirements seriously and evaluate their structures to ensure faithfulness in both spiritual and practical matters.
Key Takeaways for Churches
- Most Churches Are Exempt: If your church operates as a nonprofit under 501(c)(3), you are likely exempt from the BOI filing requirement.
- Review Your Structure: For-profit subsidiaries or related entities may have different obligations. Seek wise counsel to ensure compliance.
- Stay Vigilant: Laws and regulations can change. Stay informed, consult with legal and financial professionals, and lead your church with integrity.
While the BOI filing requirement may seem like just another bureaucratic hurdle, it provides an opportunity to reflect on our role as ambassadors for Christ. In everything we do—whether preaching, counseling, or filing paperwork—we bear witness to the gospel. May we conduct ourselves in a manner worthy of our calling, striving for excellence and faithfulness in every aspect of ministry.
This article is for informational purposes only and does not constitute legal or financial advice. Churches are encouraged to consult with legal professionals to confirm their specific obligations.