Federal Reporting Requirement: Beneficial Ownership Reporting Rule (BOI) Update
IMPORTANT UPDATE:
New Court Decision Issued Beneficial Ownership Information (BOI) Reporting Now Due March 21, 2025
The Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are back in effect, with a new filing deadline of March 21, 2025. Here’s a summary of the developments:
- Court Decisions:
- On February 17, 2025, the Federal District Court in Texas removed the injunction that had blocked BOI reporting. This aligns with a January 2025 Supreme Court decision in another BOI case.
- FinCEN Announcement:
- Following this legal development, the Financial Crimes Enforcement Network (FinCEN) confirmed that the reporting requirements are now back in effect.
- Due Date: FinCEN announced a March 21, 2025 due date to give businesses time to comply. It is uncertain if this due date will be extended.
- Legislative Developments:
- The House of Representatives unanimously passed a bill to delay the BOI reporting requirements until January 1, 2026, but it still needs Senate approval.
- The bill would apply only to businesses created before January 1, 2024, so it would not delay reporting for newer businesses.
- Uncertainty in the Future:
- There are ongoing legal appeals in the Fourth, Fifth, and Eleventh Circuits, with a hearing scheduled for April 1, 2025, in the fifth circuit. This could impact the future of the BOI requirements.
- FinCEN is also considering further revisions to reduce the reporting burden, especially for small businesses.
What Should Business Owners Do?
- Prepare for BOI filing by March 21, 2025. While there may be further delays or changes, it’s best to plan for the current deadline.
We will continue to provide updates as new developments occur.
For more information on the BOI reporting rules and earlier legal decisions, please refer to our previous article: Federal Reporting Requirement: Beneficial Ownership Reporting Rule (BOI) Filing Requirement Currently Suspended
