Update: BOI Reporting Requirement – Back On

With FinCEN's beneficial ownership reporting rules back in play and a new deadline of March 21, 2025, businesses need to stay flexible - especially with the possibility of more deadline twists!

The Financial Crimes Enforcement Network (FinCEN) has announced that the beneficial ownership reporting requirements are officially back in effect, with a new compliance deadline of March 21, 2025, for most companies. This update follows a court ruling from the Samantha Smith and Robert Means v. U.S. Department of the Treasury, which lifted the last nationwide injunction on the rules.

While this marks the third deadline shift in the past few months, there may be additional timeline changes within the next 30 days. FinCEN has also indicated it plans to revise the reporting rule this year to ease the burden on lower-risk entities, such as many U.S. small businesses.

Key Points to Remember:

• New Reporting Deadline: March 21, 2025, for initial, updated, and corrected BOI reports
  
  
• Exceptions: Entities with previously assigned later deadlines (e.g., disaster relief extensions) may retain their original filing dates

Legislative Developments:

On February 10, 2025, the House passed the Protect Small Businesses From Excessive Paperwork Act of 2025 (H.R.736), which could extend the compliance deadline to January 1, 2026 for pre-2024 reporting companies. This bill is now awaiting Senate action, but other CTA repeal bills are continuing their journey through the lengthy legislative process.

It is crucial for businesses to stay adaptable and prepared for the upcoming March deadline given the evolving nature of these requirements. If you have any questions or need assistance, please give our office a call at 602.230.1040.