What is the BOI reporting requirement for LLCs in Illinois?

Illinois does not impose a separate state-level Beneficial Ownership Information (BOI) reporting requirement for LLCs. However, if your LLC qualifies as a reporting company under the federal Corporate Transparency Act (31 U.S.C. § 5336), you must file BOI with FinCEN, not Illinois. Most LLCs formed or registered in the U.S. are reporting companies. Illinois requires only an Annual Report with the Secretary of State (805 ILCS 180/50-1, 180/50-5), which captures manager and member information but is not a BOI filing.

Federal BOI Reporting (FinCEN)

The Corporate Transparency Act requires most LLCs to report beneficial ownership information to FinCEN. You must identify all beneficial owners—individuals with 25% or greater ownership or substantial control—and file electronically at https://www.fincen.gov/boi.

Filing deadlines depend on formation date:

LLCs formed before January 1, 2024: deadline was January 1, 2025
LLCs formed after January 1, 2024: file within 90 days of formation

Non-compliance carries civil and criminal penalties, including fines up to $10,000 and potential criminal liability.

Illinois State Requirements

Illinois requires all LLCs to file an Annual Report with the Secretary of State before the first day of their anniversary month each year (805 ILCS 180/50-1, 180/50-5). The $75 filing fee is due with each report.

Required information includes:

LLC legal name and file number
Jurisdiction of organization
Principal place of business address
Names and business addresses of all managers and members with manager authority
Registered agent and registered office information

This Annual Report is not a BOI filing. It serves as Illinois's primary compliance requirement but does not satisfy federal BOI obligations.

Penalties for Non-Compliance

Missing the Illinois Annual Report deadline triggers a $100 late penalty if filed more than 60 days after the due date. If the report remains unfiled 120 days from the original due date, your LLC faces administrative dissolution or revocation (805 ILCS 180/50-5). Reinstatement requires a $200 fee plus all delinquent annual report fees and penalties.

Next Steps

Determine federal BOI status: Check if your LLC is a reporting company under the CTA at https://www.fincen.gov/boi.
File BOI with FinCEN (if applicable)—not with Illinois.
File Illinois Annual Reports with the Secretary of State at https://apps.ilsos.gov/llcarticles/index.jsp.
Contact the Illinois Secretary of State at (217) 524-8008 or https://www.ilsos.gov/ for state-specific questions.

This is general information, not legal advice.