Annual Filings
- Marshall Islands DAO LLCs complete annual filings and pay annual fees by January 31 every year. MIDAO emails the portal link in late December.
- The annual filing covers the current calendar year. For example, the filing due January 31, 2027 confirms the DAO LLC's details for 2027. For-profit DAO LLCs declare the previous calendar year's gross revenue in the same filing (2026 revenue in the 2027 filing).
- Annual filings are completed through the annual filing portal (desktop only) and include the following steps:
- Complete the annual fee payment, and verify the company's treasury and funding amount (which determines the annual fee level).
- Submit the most recent version of their Operating Agreement (if updated).
- Submit a Beneficial Owner Information Report (BOIR) (opens in new tab).
- If there are changes to who is listed on the BOIR form, the new natural or legal persons (i.e. companies) listed in the report must complete KYC/KYB.
- Learn more about beneficial ownership reporting and KYC/KYB here.
- Submit a Representative Agent Form (opens in new tab) (if the Representative Agent needs to be updated).
- Submit the Annual Filing Form (opens in new tab).
- If the DAO is for-profit, it must also report its revenue for tax purposes and pay its taxes.
Annual Filings as a Compliance Refresh
- Annual filings also serve as a compliance refresh. If the DAO LLC's ownership, governance, activities, jurisdictions, or risk profile has changed, MIDAO may require updated KYC/KYB, beneficial ownership information, Representative Agent information, source-of-funds information, treasury information, or other details as part of the filing.
Overdue Filings
If a DAO LLC's annual fees or filings are overdue, late fees apply, and:
- The DAO LLC shows as "Not in Good Standing" on the public registry, and MIDAO cannot issue it a Certificate of Good Standing.
- MIDAO pauses its services to the DAO LLC and refers it to the Registrar of Corporations, which mails paper letters to the registered agent address. These letters are not sent when fees and filings are completed on time.
- After the Registrar's notice, the DAO LLC has 30 days to fix the default. After that, the Registrar can suspend the DAO LLC, cancel its Certificate of Formation, or impose fines.
- If the annual fee goes unpaid for a year, the Registrar can revoke the DAO LLC's Certificate of Formation and dissolve it, unless the default is fixed within 90 days of the Registrar's notice.
- Good standing is restored once the overdue filing and any outstanding KYC/KYB are approved.
See Relevant RMI Laws and Regulation for the underlying rules. To avoid all of this, please complete annual filings on time through the annual filing portal.
Common Questions
Who can log in to the portal, and how do we add or change users?
- Each DAO LLC has a Primary User, and may have additional users. The Primary User is not necessarily the Representative Agent, and can add additional users for the DAO LLC.
- If you've forgotten your password, use the "Forgot Password" link on the portal login page.
- If you need help adding or changing users, please contact MIDAO.
Our filing says "Under Review" or "Pending." Is anything else needed?
- Usually only beneficial owner KYC/KYB is left (see Common KYC Issues). MIDAO emails the KYC/KYB link after reviewing your documents, and confirms by email or Telegram once the filing is approved.
We made a mistake in a submission. Can we fix it?
- Yes. Tell MIDAO which form or document is wrong. MIDAO can reset a web form so you can submit it again, or replace an uploaded document, such as an amended Operating Agreement, that you email in.