Beneficial Ownership Information (BOI) Reporting Mandate Reinstated: New Deadline Set for March 21, 2025

On February 18, 2025, the U.S. District Court for the Eastern District of Texas lifted the preliminary injunction in Smith, et al. v. U.S. Department of the Treasury, et al. (Case No. 6:24-cv-00336), effectively reinstating the Beneficial Ownership Information (BOI) reporting mandate under the Corporate Transparency Act. Following this decision, the Financial Crimes Enforcement Network (FinCEN) has announced that the BOI filing requirement is back in effect, with a new compliance deadline of March 21, 2025.

Who Must File?

The updated BOI reporting deadline applies to:

• All reporting companies, including entities formed prior to January 1, 2024, that are required to submit an initial, updated, or corrected BOI report.

• Entities formed in 2025 must file by the later of March 21, 2025, or 30 days from their formation date.

FinCEN’s Next Steps

FinCEN has indicated that over the next 30 days, it will evaluate further deadline modifications while prioritizing reporting for entities that pose the most significant national security risks. Additionally, FinCEN intends to revise the BOI reporting rule later this year to reduce compliance burdens for lower-risk entities, including many U.S. small businesses.

For more information and official updates, visit the FinCEN notice:

FinCEN BOI Reporting Notice.

If you need assistance ensuring compliance with BOI reporting requirements, contact Jon today.