FinCEN Reinstates BOI Reporting: New Deadline Set for March 21, 2025

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Following a series of legal reversals, the U.S. District Court for the Eastern District of Texas has granted a stay on its previous injunction that had blocked enforcement of the Corporate Transparency Act (CTA) and its Beneficial Ownership Information (BOI) reporting rule. As a result, the Financial Crimes Enforcement Network (FinCEN) is once again authorized to enforce BOI reporting requirements.

Key Updates on BOI Reporting

The new compliance deadline for most businesses to file their initial, updated, or corrected BOI reports is March 21, 2025. Companies that had previously been granted extended deadlines due to disaster relief exemptions must still adhere to those specific timelines. FinCEN has made it clear that reporting obligations are now in effect and enforcement will continue unless further legal developments arise.

Who is Affected?

  • Most businesses that meet the CTA’s reporting criteria must comply with BOI reporting requirements by March 21, 2025.
  • Plaintiffs involved in National Small Business United v. Yellen are temporarily exempt from reporting until further notice.
  • Companies should evaluate their status under the CTA and take steps to ensure they meet compliance requirements.

What Led to This Decision?

The BOI reporting mandate has faced multiple legal challenges over the past few months. In December 2024, a nationwide injunction in Texas Top Cop Shop, Inc. v. McHenry temporarily blocked the enforcement of CTA reporting requirements. However, on January 23, 2025, the U.S. Supreme Court stayed the injunction, effectively restoring FinCEN’s authority to require BOI reporting. This ruling was reinforced on February 18, 2025, when the U.S. District Court for the Eastern District of Texas officially lifted its own injunction, making BOI compliance mandatory once again. These rulings clarify that businesses must now comply with CTA reporting regulations unless further legal developments arise.

 

 

Potential Future Changes

  • FinCEN is considering regulatory adjustments to reduce compliance burdens for certain businesses.
  • The agency may extend deadlines for low-risk entities and small businesses to ease reporting obligations.
  • The U.S. House of Representatives has passed a bill extending the BOI reporting deadline to January 1, 2026, but Senate approval is still pending.
  • Additional legislative efforts could further impact deadlines or reporting requirements.

 

What Businesses Should Do Now

  • Review your BOI reporting obligations under the Corporate Transparency Act.
  • Prepare and submit BOI reports by March 21, 2025, to remain compliant.
  • Monitor updates from FinCEN for possible deadline extensions or rule modifications.

 

Disclaimer

Melton & Melton, LLP does not assist clients in complying with the Corporate Transparency Act and its Beneficial Ownership Information reporting requirements. Information regarding the BOI reporting requirements can be found at https://www.fincen.gov/boi. We suggest consulting with legal counsel if you have questions regarding the applicability of the CTA’s reporting requirements and issues surrounding the collection of relevant ownership information.