BOI Reporting Lives Again – For Now.

March 21, 2025, is the new due date, but litigation and pending legislation could change it – again.

Earlier this week, the Beneficial Ownership Information (“BOI”) filing obligations were reinstated, with a new filing deadline set for March 21, 2025.  Affected entities should take prompt steps to comply.

The U.S. District Court that had previously prohibited the US Treasury from enforcing BOI filing obligations under the Corporate Transparency Act (“CTA”) has now stayed its injunction based on the Supreme Court’s lifting of a similar injunction by another court.  FinCEN then promptly announced that enforcement of the BOI filing requirement would resume.

https://fincen.gov/sites/default/files/shared/FinCEN-BOI-Notice-Deadline-Extension-508FINAL.pdf

CTA’s merits remain under review by the Fifth Circuit, which could reinstate the injunction or uphold the filing obligation, but timing of any such decision is uncertain.

On the legislative front, a bill authorizing FinCEN to delay the filing of BOI reports until January 2026 passed the House of Representatives unanimously.  The bill moves on to the Senate, where a companion bill has already been introduced.

On the regulatory front, FinCEN announced that during the extension period to March 21, it will start a process to revise the reporting rules, but it seems unlikely that process would be complete before the new deadline to file reports.

Stay tuned.

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