BOI Reporting Requirements: A Timeline of Recent Changes

Last Updated: March 3, 2025

March 2, 2025: BOI Reporting Suspended for Domestic Entities

The US Department of Treasury announced the suspension of Beneficial Ownership Information (BOI) reporting requirements for all US domestic reporting entities. Key points:

  • No penalties will be enforced for domestic entities not filing BOI reports

  • No further action required at this time for domestic companies

  • Foreign reporting companies still must comply with BOI requirements

  • FinCEN expected to provide additional guidance, particularly regarding foreign reporting companies

  • State-level compliance deadlines and BOI reporting requirements (such as those in New York and Washington D.C.) remain in effect

This represents another significant delay in the implementation of the Corporate Transparency Act's reporting requirements, which have faced multiple extensions and modifications since their initial implementation date.

References: US Dept. of Treasury Press Release, Agency Guidance Document

The Corporate Transparency Act's Beneficial Ownership Information (BOI) reporting requirements have undergone several significant changes in recent months.

February 18, 2025: BOI Reporting Requirements Back on Hold

BIG update on BOI filing - it's back in effect with new deadlines following the February 18, 2025 court decision!

Key Updates:

  • BOI reporting requirements are back in effect following the U.S. District Court for the Eastern District of Texas decision

  • NEW DEADLINE: March 21, 2025 for most companies

  • FinCEN is providing this 30-day extension from February 19, 2025

  • Companies with later deadlines (like those with disaster relief extensions) should keep their original deadlines

Need Help Filing?

We have a full step by step walkthrough on how to file your BOI Filing inside the [Financially Focused Collective]

Quick Background: A Texas court initially stayed the BOI requirements on January 7, 2025. The Department of Justice appealed on February 5, 2025, and on February 18, 2025, the court agreed to stay its previous order. This means BOI reporting is now mandatory again, with the extended deadline to help companies comply.

Stay tuned for any further updates from FinCEN before the March 21 deadline!

๐Ÿ“–[What is the BOI Filing and Corporate Transparency Act (CTA)]

Here's a comprehensive timeline of events, with the most recent developments first:

December 26, 2024: BOI Reporting Requirements Back on Hold

The Fifth Circuit Court of Appeals has vacated its previous stay, effectively putting BOI filing requirements back on hold. Key implications:

  • All reporting deadlines, including the January 13, 2025 compliance date, are now suspended

  • FinCEN will provide updated guidance once legal issues are resolved

  • No penalties will be enforced during this period of uncertainty

December 23, 2024: Fifth Circuit Reinstates BOI Requirements

The U.S. Court of Appeals for the Fifth Circuit temporarily lifted the nationwide injunction, briefly reinstating reporting requirements with adjusted deadlines:

  • Pre-2024 entities: Extended deadline to January 13, 2025

  • Entities created/registered between September 4-December 3, 2024: January 13, 2025 deadline

  • Entities created/registered December 3-23, 2024: 21-day extension from original deadline

  • Post-January 1, 2025 entities: 30 days from creation/registration notice

  • Special exemption: National Small Business United v. Yellen plaintiffs remain exempt

December 3, 2024: Nationwide Injunction Issued

๐Ÿ“–[More about the Dec 3, 2024 Injunction]

The U.S. District Court for the Eastern District of Texas issued a nationwide injunction:

  • Halted enforcement of the Corporate Transparency Act

  • FinCEN confirmed compliance with the injunction

  • Suspended requirement for reporting companies to file beneficial ownership information

  • No penalties for failing to file during the injunction period

Important Considerations for Businesses

Despite the current hold on requirements, businesses should consider:

  1. Preparedness Strategy

    • Gather necessary information now to be ready for potential quick turnaround

    • Review entity structure and beneficial ownership details

    • Consider voluntary filing to ensure compliance regardless of outcome

  2. Potential Penalties When Reinstated

    • Civil penalties: $591 per day

    • Criminal fines: Up to $10,000

    • Potential imprisonment: Up to two years

  3. Best Practices

    • Monitor FinCEN updates regularly

    • Maintain documentation readiness

    • Consider filing proactively if privacy concerns are minimal

    • Keep track of applicable deadlines and extensions

Need Help With BOI Filing?

Get expert guidance through the entire BOI filing process with our comprehensive BOI Filing Masterclass. Inside this step-by-step course, you'll learn:

  • How to navigate the FinCEN website

  • Complete walkthrough of the filing process

  • Tips for gathering required information

  • Common pitfalls to avoid

  • Expert insights on compliance requirements

๐Ÿ‘‰ Get instant access to the BOI Filing Masterclass inside the [Financially Focused Collective]

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