March 3, 2025: The Treasury Department announced on March 2, 2025, that it will not enforce any penalties or fines associated with beneficial ownership reporting on US citizens or domestic reporting companies. It also plans on revisiting the rules to narrow the scope of the BOI reporting rules under the law to foreign reporting companies only. The original information published in our article, Beneficial Ownership Information (BOI) Reporting is Back, may no longer be an accurate representation of current legislative status or information.
The Last Remaining Nationwide Injunction Stopping BOI Filing Requirements Has Been Lifted
On February 18, 2025, the U.S. District Court for the Eastern District of Texas lifted the last remaining nationwide injunction stopping BOI filing requirements. FinCEN announced that the new filing deadline is March 21, 2025. This new deadline applies to most reporting companies to file an initial, updated, or corrected BOI report, including those entities filed prior to January 1, 2024. Entities formed in 2025 must file by the later of March 21, 2025, or 30 days from the date of formation.
FinCEN indicated that during the next 30 days, it will “assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks. FinCEN also intends to initiate a process this year to revise the BOI reporting rule to reduce the burden for lower-risk entities, including many U.S. small businesses.”
If your organization is subject to the BOI filing requirement and you have not already submitted your report, we strongly recommend doing so before March 21, 2025, rather than waiting to see if FinCEN modifies the existing deadline.
Please review this notice for further information or contact us if you need assistance.