FinCEN Beneficial Ownership Information Reporting Deadline Extended
FinCEN Beneficial Ownership Information Reporting Deadline Extended
In an important update for businesses navigating the Corporate Transparency Act (CTA), the
Financial Crimes Enforcement Network (FinCEN) has announced a 30-day extension for most
companies required to file Beneficial Ownership Information (BOI) reports. This decision follows a
recent ruling by the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S.
Department of the Treasury, et al.
Background and Legal Developments
Earlier this year, on January 7th, The U.S. District Court for the Eastern District of Texas issued a
court order temporarily blocking FinCEN from enforcing BOI reporting requirements. Then, on
February 5th, the U.S. Department of Justice filed a notice of appeal of the district court’s order and
asked for a stay of that order until the appeal is complete. On February 18, 2025, the court issued
the requested stay, reinstating the reporting mandates during the appeal process.
Key Takeaways from FinCEN’s Announcement
- Extended Deadline: Most reporting companies formed before February 19, 2025 now
have until March 21, 2025, to submit their initial, updated, and/or corrected BOI reports. If
you form(ed) an entity after February 19, 2025 that meets the definition of a “reporting
company” and does not qualify for an exemption, you have 30 days from the date of
formation to file the BOI. - Possible Further Extensions: FinCEN is evaluating additional modifications to deadlines,
particularly prioritizing reporting from entities posing significant national security risks. - Revising the BOI Reporting Rule: FinCEN is assessing additional options to ease
compliance burdens, particularly for small businesses. - Exceptions for Certain Companies: Entities that have previously been allowed a
reporting deadline after March 21, 2025, such as those that qualified for disaster relief
extensions or the plaintiffs in National Small Business United v. Yellen, remain subject to
the later deadline.
What Businesses Need to Do Next
Impacted entities can review the FinCEN’s Small Entity Compliance Guide for details on whether
or not they are required to file a BOI report and to better understand any obligations they may
have and ensure compliance before their filing deadline. Reports can be filed free of charge via
FinCEN’s E-Filing system at https://boiefiling.fincen.gov.
For more details, you can read FinCEN’s full announcement here: FinCEN Update.
InSight Law is an estate and business planning law firm. If you are interested in learning more
about estate planning, our firm’s process, and related fees, please sign up for one of our free
training seminars.