If you formed your company January 1, 2024 or after, you will have to provide details about your Company Applicant. This is a person!

FinCEN defines a company applicant to be only two persons(1):

• the individual who directly files the document that creates the entity, or in the case of a foreign reporting company, the document that first registers the entity to do business in the United States.
• the individual who is primarily responsible for directing or controlling the filing of the relevant document by another.

Company Applicant could be your lawyer or other professional who filed your company documents

This means that if you hired someone, such as a lawyer or formation service, to create the business on your behalf, they would be listed as the company applicant​​.

For your BOI report, you will need Company Applicant details from them:

• The company applicant's name, address, and identifying information to populate in your report OR 
• FinCEN ID (if applicable)

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If you used an automated incorporation service, such as Stripe Atlas, who is the Company Applicant?

For automated incorporation service, such as through a website or online platform, (such as Stripe Atlas, (1)) Companies should list the account owner (the founder who submitted their company’s Atlas application) as the company applicant. Atlas companies do not need to list any other parties (including Stripe Atlas) as company applicants, nor provide their FinCEN ID.(1)

This means if you used an automated incorporation service and filled out / submitted your company’s application, you are considered the company applicant and would populate your own information in this section. 

For more information, See FinCEN’s FAQ’s.

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Not sure if you used an automated incorporation service?

FinCEN says: 

If a business formation service only provides software, online tools, or generally applicable written guidance that are used to file a creation or registration document for a reporting company, and employees of the business service are not directly involved in the filing of the document, the employees of such services are not company applicants. For example, an individual may prepare and self-file documents to create the individual’s own reporting company through an automated incorporation service. In this case, this reporting company reports only that individual as a company applicant.

For more information, See FinCEN’s FAQ’s.

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Conclusion

Company Applicant is the person (or people) who filed your initial business paperwork with the Secretary of State. This could be your lawyer, other legal professional, or even you if you filed with an automated incorporation service.