Important Updates on BOI Filing Requirements and the Corporate Transparency Act
As businesses navigate the changing landscape of the Corporate Transparency Act (CTA) and the Beneficial Ownership Information (BOI) filing requirements, it's crucial to stay informed of the latest developments. Below, we've summarized recent updates and provided clarity on what they mean for your reporting obligations.
BOI enforcement is halted pending FinCEN’s announcement of a new deadline
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BOI enforcement is halted pending FinCEN’s announcement of a new deadline ♦
Key Updates:
2/28/2025
FinCEN will be suspending the enforcement of the March 21st deadline and will be providing an additional extension to be announced before March 21st. FinCEN said it will not take any enforcement actions, including not issuing fines or penalties based on a failure to file or update BOI reports by the current deadlines. They recognize the need to provide additional guidance and clarity as quickly as possible.
2/17/2025
The last remaining Nationwide injunction halting the filing requirements was lifted. FinCEN announced that it will grant businesses until March 21st to file their beneficial ownership information reports. Meanwhile, the bill in Congress passing the House on the 10th remains with the Senate awaiting a vote to determine if the requirement will be delayed until Jan. 1, 2026.
2/10/2025
The House passed H.R. 736 Protect Small Businesses From Excessive Paperwork Act of 2025, 408-0. The bill currently rests with the Senate. If approved the bill extends the deadline for filing BOI reports to Jan. 1. 2026.
1/23/2025
The Supreme Court has lifted the preliminary injunction, thereby allowing FinCen to enforce the BOI requirements again. We are waiting for a formal response from the Trump administration and FinCEN to issue updated guidance on the specifics and timing for BOI reporting deadlines.
12/31/2024
The Department of Justice has filed to stay the preliminary injunction with the Supreme Court. There is no clear indication when the Supreme Court will rule on this filing. See the article from Journal of Accountancy here.
12/27/2024
The Fifth Circuit Court issued an expedited briefing schedule. Oral arguments regarding the constitutionality of the Corporate Transparency Act’s Beneficial Ownership Reporting requirement are scheduled for March 25, 2025.
12/26/2024
The Fifth Circuit Court of Appeals convened an En Banc Session and reinstated the nationwide preliminary injunction. This ruling pauses the BOI filing requirement until the case is resolved. FinCEN’s updated alert clarifies that:
Companies are not currently required to file BOI reports.
There is no liability for failing to file while the injunction is in place.
Companies may choose to submit reports during this period voluntarily.
