BOI Reporting Back in Effect
As of February 18, 2025, the Corporate Transparency Act (CTA) beneficial ownership information (BOI) reporting requirements are once again in effect. This follows a ruling by the U.S. District Court for the Eastern District of Texas, which lifted the last nationwide injunction in Smith v. U.S. Department of the Treasury (6:24-cv-00336).
In response, FinCEN issued guidance on February 19, 2025, extending the BOI filing deadline for most reporting companies to March 21, 2025—providing an additional 30 days for compliance. FinCEN will continue to evaluate whether further deadline modifications are necessary during this period.
Key Exception: The plaintiff group in National Small Business United (133 AFTR 2d 2024-885 (D.C., AL)) remains exempt from BOI reporting requirements.
Companies required to file BOI reports can do so through FinCEN’s E-Filing system at https://boiefiling.fincen.gov.
We recommend that you take the time to review your entity’s obligations under the CTA. If you are unsure about how to proceed, we encourage you to consult with your legal counsel to ensure all required documentation is completed accurately and submitted on time. Otherwise, please refer to the Beneficial Ownership Information Reporting website made available via the Financial Crimes Enforcement Network: https://fincen.gov/boi.