Following the February 18, 2025, decision by the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al., Beneficial Ownership Information (BOI) reporting requirements are back in effect under the Corporate Transparency Act (CTA).
To allow businesses more time to comply, the Financial Crimes Enforcement Network (FinCEN) is extending the BOI reporting deadline by 30 days from February 19, 2025, with most reporting companies now required to file by March 21, 2025.
Key Updates:
- Injunction lifted — BOI reporting rules are now fully reinstated following the February 18, 2025, court decision in Smith, et al. v. U.S. Department of the Treasury, et al.
- New March 21, 2025, deadline — Most reporting companies must submit their initial, updated, or corrected BOI reports by March 21, 2025 (30 days from February 19, 2025).
- Existing later deadlines still apply — If a company already had a BOI filing deadline beyond March 21, 2025 (e.g., those qualifying for disaster relief extensions), it should follow that later deadline.
- Small business association exception — Plaintiffs in National Small Business United v. Yellen, including Isaac Winkles and certain National Small Business Association members (as of March 1, 2024), are not required to report now.
- Potential further deadline modifications — FinCEN is evaluating more deadline adjustments and plans to revise BOI reporting rules to reduce burdens on small businesses while prioritizing higher-risk entities.
Why This Matters for Your Business
Failure to comply with BOI reporting requirements can lead to significant penalties, including fines of up to $606 per day (capped at $10,000) and potential criminal liability. To stay compliant, businesses should first decide whether they qualify as a reporting company, then find beneficial owners and collect the necessary details.
Companies must also ensure they file reports within applicable deadlines and update their filings if ownership details change. Taking these steps now can help your business avoid costly penalties and regulatory issues.
Next Steps
Navigating BOI compliance can be complex, but taking action now can help avoid penalties. Read more about enforcement risks and compliance strategies here.
Have questions about BOI reporting requirements? Contact us today to be connected with professionals who can help.