Following a decision in federal court on February 18, 2025, Beneficial Ownership Information (BOI) reporting is once again a requirement for most businesses under the Corporate Transparency Act (CTA). This means all companies must complete BOI reporting by March 21, 2025 or face a steep penalty of $591 per day until the BOI is filed.
Newest BOI Reporting Deadlines
- March 21, 2025: For the vast majority of reporting companies, the new deadline to file an initial, updated, and/or corrected BOI report is now March 21, 2025.
- Extended Deadlines Remain Extended: Reporting companies that were previously given a reporting deadline later March 21, 2025 can maintain their stated deadline. For example, if a company’s reporting deadline is in April 2025 because it qualifies for certain disaster relief extensions, it should follow the April deadline, not the March deadline.
- 30 Days from Formation: Any entity created or registered on or after January 1, 2025 have 30 days to file after their registration is effective.
BOI Reporting History
2021 Corporate Transparency Act: Congress passed the Corporate Transparency Act (CTA) in 2021 as a was to deter money laundering, terrorist financing, tax fraud, and other illicit activity. BOI reporting requires companies to disclose the identity and information about beneficial owners of entities. Additionally, any entity incorporated after January 1, 2024 is required to disclose the identity of “company applicants” or any individual who files an application to form a corporation, LLC, or other similar entity.
Beginning in December 2024, federal courts in Texas started filing injunctions to temporarily block the enforcement of the CTA and this reporting rule. This moved the original filling deadline from January 1, 2025 to January 13, 2025.
- January 13, 2025: This was the original deadline for entities created prior to 2024.
- January 7, 2025 Injunction: The Eastern District of Texas issued two separate nationwide injunctions, halting the CTA and its reporting requirement.
- February 18, 2025: Both injunctions were lifted while the Fifth Circuit Court of Appeals continues to prepare to hear oral argument on the constitutionality of the CTA. FinCEN issued a 30-day delay for reporting, setting the newest deadline of March 25, 2025.
- March 21, 2025: The current deadline for BOI reporting.
Potential BOI Reporting Changes Coming
While the March 21, 2025 deadline is the current standing for BOI reporting, Congress is actively considering legislation that could impact compliance timelines, such as the following:
- Protect Small Businesses from Excessive Paperwork Act of 2025: this was passed on February 10, 2025 by the U.S. House of Representatives and would extend the BOI filing deadline to January 1, 2026.
- Repealing Big Brother Overreach Act: this has been reintroduced in the Senate and House, which, if enacted, would fully repeal the CTA.
- Court cases: there are several ongoing court cases that could impact the long-term enforceability of the CTA.
Please note that current law requires the BOI reporting to be completed by March 21. Due to the extreme penalties assessed for noncompliance, it is our recommendation to proceed with your filing to ensure your entity is not subject to fines.
Avizo Group can assist our current clients with meeting this filing requirement. We use a secure online portal that simplifies the collection of your information. Please email us at [email protected] or contact one of our Avizo team members at 251-928-2443 if you would like some help with ensuring you meet this filing requirement.
Erann Thompson, Principal & Director of Advisory Services
Erann collaborates closely with business owners to identify the optimal mix of accounting cloud applications, aiming to enhance efficiency and profitability for your business.
