February 20, 2025
On February 18, 2025, the U.S. District Court for the Eastern District of Texas reinstated the Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA) following its decision in Smith, et al. v. U.S. Department of the Treasury, et al., Case No. 6:24-cv-00336 (E.D. Tex.). This decision lifts the previous stay on FinCEN’s enforcement of the rule, making BOI reporting mandatory once again.
However, recognizing the compliance challenges businesses face, the Financial Crimes Enforcement Network (FinCEN) has extended the BOI reporting deadline by 30 days, with most companies now required to file by March 21, 2025.
Key Updates on BOI Reporting Deadlines
FinCEN has issued updated guidance regarding BOI reporting obligations:
- New Deadline for Most Reporting Companies
- Companies that were previously required to report by February 19, 2025, now have until March 21, 2025, to file an initial, updated, or corrected BOI report.
- FinCEN may announce further modifications before this new deadline.
- Later Deadlines for Certain Entities
- Companies that had a later reporting deadline due to disaster relief extensions or other special circumstances must adhere to their originally assigned deadline (e.g., April 2025 filers still follow the April deadline).
- Exemptions for Certain Businesses
- Entities involved in National Small Business United v. Yellen (Case No. 5:22-cv-01448 (N.D. Ala.)) remain exempt from reporting at this time.
- This exemption includes Isaac Winkles, any companies where he is a beneficial owner, and members of the National Small Business Association (as of March 1, 2024).
- Filing Process
- BOI reports must be filed electronically through FinCEN’s E-Filing system at boiefiling.fincen.gov.
- Filing remains free of charge.
Why Did the BOI Reporting Deadline Change?
This extension follows a series of legal challenges against the Corporate Transparency Act’s reporting rules:
- January 7, 2025 – The U.S. District Court for the Eastern District of Texas issued a stay preventing FinCEN from enforcing BOI reporting requirements.
- February 5, 2025 – The U.S. Department of Justice appealed the ruling and requested a stay of the court’s order.
- February 18, 2025 – The court agreed to stay its January 7 order pending the appeal, effectively reinstating BOI reporting obligations.
- Ongoing Legal Review – FinCEN plans to revise its BOI reporting rule to reduce regulatory burdens on lower-risk businesses, particularly small businesses.
What This Means for Your Business
Businesses subject to BOI reporting must comply with the new March 21, 2025, deadline unless they qualify for a later reporting date. Failure to comply could result in penalties, making it critical for companies to review their filing obligations as soon as possible.
Additionally, with FinCEN signaling a future rule revision, businesses should stay informed about potential modifications to BOI reporting requirements, particularly for low-risk entities.
If you need assistance determining your BOI reporting obligations, filing your report, or understanding potential exemptions, our law firm is here to help. Contact us today at julie@mokslaw.com for compliance guidance and legal counsel tailored to your business.
Stay Compliant with BOI Reporting
Our firm is closely monitoring these regulatory developments and can assist with:
✅ Determining whether your company must report BOI
✅ Filing your BOI report accurately and on time
✅ Identifying exemptions and compliance strategies
✅ Navigating ongoing legal changes to the CTA
For expert legal guidance, contact us today at julie@mokslaw.com to ensure your business remains compliant with the latest FinCEN reporting requirements.