BOI Reporting Requirements Back in Effect as of February 18, 2025, Following Court Ruling
BOI reporting under the Corporate Transparency Act (CTA) is back in effect as of February 18, 2025. Businesses must comply with FinCEN’s updated deadlines. The new filing deadline is March 21, 2025, with some exceptions. Learn how to stay compliant.
After a rollercoaster of legal reversals, a February 18, 2025, ruling in Smith, et al. v. U.S. Department of the Treasury, et al. has reinstated BOI reporting requirements under the Corporate Transparency Act (CTA), requiring businesses to comply with FinCEN's reporting deadlines. reinstated BOI reporting requirements under the Corporate Transparency Act (CTA). As a result, businesses must comply with FinCEN's updated deadlines and regulatory obligations., BOI reporting requirements under the Corporate Transparency Act (CTA) are once again in effect. The decision, issued by the U.S. District Court for the Eastern District of Texas, reinstates compliance obligations for reporting companies.
Extended Deadline for BOI Reporting
Acknowledging the shifts in BOI reporting status, the Department of the Treasury has directed FinCEN to extend the deadline by 30 calendar days from February 19, 2025 for most companies.
During this period, FinCEN will evaluate options to further modify deadlines while prioritizing BOI reporting for entities that present the highest national security risks. Additionally, FinCEN plans to initiate revisions to the BOI reporting rule this year to ease the burden on lower-risk entities, including many small businesses in the U.S.
Updated Reporting Deadlines
For most reporting companies, the new deadline to file an initial, updated, or corrected BOI report is March 21, 2025. FinCEN will provide further updates if additional deadline modifications occur.
Companies with previously extended reporting deadlines (e.g., those granted disaster relief extensions) must follow their original deadlines. If a company’s reporting deadline is in April 2025, it must adhere to that schedule instead of the March deadline.
As indicated in the alert Notice Regarding National Small Business United v. Yellen, No. 5:22-cv-01448 (N.D. Ala.), plaintiffs in that case—including Isaac Winkles, the National Small Business Association, and its members (as of March 1, 2024)—are currently not required to submit BOI reports.
For further litigation updates related to the Corporate Transparency Act and its effect on reporting obligations, refer to FinCEN alerts. Additionally, explore related insights such as:
U.S. Supreme Court’s decision lifting the injunction on the Corporate Transparency Act
What businesses need to know about the Corporate Transparency Act For additional insights on the Corporate Transparency Act, explore:
U.S. Supreme Court’s decision lifting the injunction on the CTA
CTA deadline reminders Additionally, explore related insights such as the U.S. Supreme Court’s decision lifting the injunction on the Corporate Transparency Act, FinCEN’s latest guidance in BOI filing updates, and the nationwide injunction that temporarily halted CTA reporting.
How to File a BOI Report and Legal Support from MZLS
File your BOI report now to ensure compliance through FinCEN’s E-Filing system at https://boiefiling.fincen.gov. More details and guidance are available at fincen.gov/boi. For expert legal guidance on BOI compliance, reporting deadlines, and Corporate Transparency Act obligations, contact MZLS. Our team of experienced attorneys, including Bianca S. Sánchez-Rivera, is ready to assist businesses in navigating regulatory complexities and ensuring compliance with FinCEN requirements.