In another about-face in the Beneficial Ownership Information (BOI) reporting saga, a federal district court lifted the final nationwide injunction that had put the filings on hold since December. The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has announced the new BOI filing deadline for reporting companies is now March 21, 2025.
Key Takeaways:
BOI Reporting is now reinstated: Reporting companies must file their BOI reports unless further legal or legislative actions cause delays.
The deadline to file is March 21, 2025: Reporting companies have until March 21 to file an initial, updated, or corrected BOI report.
Reporting companies that were previously given a reporting deadline later than March 21, 2025 must file by that later deadline: For example, if a company’s reporting deadline is in October 2025 because it qualifies for certain disaster relief extensions, it should follow the October deadline.
BOI reporting is the result of The Corporate Transparency Act, which is an anti-money laundering law that directs businesses to report their ownership structures to FinCEN, overseen by the Treasury Department. The thinking is that clear ownership structures make it more difficult for bad actors to use shell companies for illicit activities like money laundering or drug trafficking.
The following current information will have to be reported about each of the company’s beneficial owners:
Unique number and issuing jurisdiction from a passport, driver’s license, or state ID, and an image of the document;
Legal name;
Birthdate; and
Residential address.
As most of our clients are aware, we are not personally completing this service however, there are free self reporting options as well as services provided by Montero Corporate Services here: https://monterocorporate.com/boi-information-at/.
FinCEN said that it would "assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks. FinCEN also intends to initiate a process this year to revise the BOI reporting rule to reduce burden for lower-risk entities, including many U.S. small businesses."
FinCEN also said it would provide an update "of any further modification of this deadline, recognizing that reporting companies may need additional time to comply with their BOI reporting obligations once this update is provided.”
This might not be the end of this particular roller-coaster, with the House of Representatives recently passing a bipartisan bill to extend the BOI reporting into 2026, which has yet to be voted on by the Senate. We will keep updates coming as this continues to unfold!
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