After a decision by the U.S. District Court for the Eastern District of Texas on February 18, beneficial ownership information (BOI) reporting requirements are back in effect. The Financial Crimes Enforcement Network (FinCEN) has announced a new reporting deadline of March 21, 2025 for most reporting companies. Companies previously granted a deadline later than March 21 will be allowed to file by the later deadline.
FinCEN is currently assessing the possibility of modifying deadlines further. The agency also announced its intention to revise the BOI reporting rules to reduce the burden for lower-risk entities, including small businesses.
We are also monitoring the status of a bill recently passed in the House of Representatives, now up for vote in the Senate, that would delay the BOI filing requirement until January 1, 2026.
These most recent developments come after a temporary suspension of BOI reporting requirements due to a federal court injunction. The lifting of the nationwide injunction allows the federal government to enforce the Corporate Transparency Act (CTA), effectively requiring businesses to file beneficial ownership information reports once again.
Ongoing debates over the constitutionality of the Corporate Transparency Act have resulted in a legal volley over the past year, with BOI reporting requirements intermittently placed on hold and resuming again in accordance with the court decisions.
We are monitoring the situation and will keep you updated on any further announcements from FinCEN regarding deadline modifications. For now, most companies will need to file their BOI reports by March 21, 2025. Our firm will not file the report on behalf of our clients.
All reports must be submitted via the BOI E-filing portal. After the initial filing, businesses only need to make updates if the information reported in the initial filing changes; there is no annual filing requirement.
Failure to file, providing false information, or failure to update BOI data when changes occur can result in civil fines of up to $606/day for each day a violation continues, and criminal penalties of up to two years imprisonment and a fine of up to $10,000.
For additional information, you can visit the FinCEN website. The Small Business Resources page includes a compliance guide, up-to-date FAQs, a quick reference, videos, and more.
PLEASE NOTE: Our affiliate, RBT CPAs is an accounting firm and does not give legal advice. Please contact your legal counsel if you need details or direction on the Corporate Transparency Act. However, if you need any accounting, tax, audit, or advisory support, please know RBT CPAs is here for you.