The landscape of Beneficial Ownership Information (BOI) reporting has shifted significantly in 2025. With recent court rulings and pending legislation, businesses must stay informed about their reporting obligations. Here’s a breakdown of the latest updates, key deadlines, and what companies need to do to remain compliant.
Court Ruling Lifts Nationwide Injunction on BOI Filing
On February 18, 2025, the federal district court lifted the final nationwide injunction that had been preventing the enforcement of BOI filing requirements. This ruling means that all businesses subject to BOI reporting must prepare to meet their filing obligations promptly.
FinCEN’s 30-Day Reporting Extension
Recognizing the potential challenges businesses may face with this sudden change, the Financial Crimes Enforcement Network (FinCEN) issued an alert on February 6, 2025, outlining an extension policy. If the court’s decision is upheld, FinCEN intends to extend the reporting deadline for all affected businesses by 30 days from the date the stay is granted.
Additionally, FinCEN will assess options to modify deadlines for low-risk entities, particularly small businesses, while prioritizing compliance for companies that pose higher national security risks.
Currently, FinCEN has not provided updated filing dates on its official website, so businesses should monitor announcements closely.
Current BOI Filing Deadlines
For now, businesses have until March 21, 2025, to submit BOI reports without facing penalties. However, certain exemptions apply:
- Businesses granted extensions due to natural disasters (e.g., Hurricanes Debby, Francine, Helene, and Milton) now have until April 23, 2025, to file.
- Entities affected by Hurricane Beryl were initially granted an extension until February 6, 2025, but must now comply with the March 21 deadline.
Companies should verify their specific deadlines to ensure timely compliance and avoid penalties.
Pending Legislation: Relief for Pre-2024 Entities?
A legislative proposal in Congress, the Protect Small Businesses from Excessive Paperwork Act of 2025 (H.R. 736), aims to provide relief for businesses established before January 1, 2024. If passed, this bill would postpone BOI reporting requirements for these entities until January 1, 2026.
The bill successfully passed the House of Representatives and is currently awaiting action in the Senate. If approved, this would provide additional time for many businesses to comply.
Key Takeaways for Businesses
- March 21, 2025, remains the main deadline for most businesses to file their BOI reports penalty-free.
- Disaster-affected businesses have extended deadlines (April 23, 2025, for specific cases).
- If pending legislation is approved, companies formed before January 1, 2024, may have until January 1, 2026, to comply.
- Companies formed in 2024 and later years should await further FinCEN guidance, as their reporting deadlines remain uncertain.
What Should Businesses Do Now?
- Verify your reporting deadline based on your business formation date and any granted extensions.
- Monitor FinCEN’s website for updated information on filing requirements.
- Stay informed about H.R. 736, which could impact reporting timelines for pre-2024 businesses.
- Consult with an expert to ensure full compliance and avoid potential fines.
For further guidance or personalized assistance, contact our office today. We can help you navigate BOI reporting requirements and ensure your business stays compliant.
