After a whiplash-inducing series of court orders, the mandatory Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are now back in effect. Most covered Reporting Companies will need to submit their BOI information to FinCEN by Mar. 21, 2025, if they have not already done so.
As set forth in a Feb. 18, 2025, FinCEN alert, the U.S. District Court for the Eastern District of Texas issued an order on that date, lifting a stay it issued on Jan. 7, 2024, which placed BOI reporting requirements on hold. As such, “BOI reporting is now mandatory.”
However, FinCEN acknowledged “that reporting companies may need additional time to comply with their BOI reporting obligations,” which is why it is generally extending the deadline 30 calendar days from Feb. 19, 2025, for most companies.”
The new BOI reporting deadlines are as follows:
- For the vast majority of reporting companies, the new deadline to file an initial, updated, and/or corrected BOI report is now Mar. 21, 2025. FinCEN will provide an update before then regarding any further modification of this deadline, recognizing that reporting companies may need additional time to comply with their BOI reporting obligations once this update is provided.
- Reporting companies that were previously given a reporting deadline later than the Mar. 21, 2025, deadline must file their initial BOI report by that later 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.
Reporting companies can report their beneficial ownership information directly to FinCEN for free using FinCEN’s E-Filing system, which is available at https://boiefiling.fincen.gov. More information is available at fincen.gov/boi.
If you have questions about the reinstatement of the injunction or the CTA generally, please contact Thomas Gironda at Ansell Grimm & Aaron.
