Small business owners must once again take note of shifting compliance requirements regarding the Corporate Transparency Act (CTA). Late Tuesday, February 18, 2025, a District Judge in Texas lifted a temporary injunction that had barred the Financial Crimes and Enforcement Network (FinCEN) from enforcing Beneficial Ownership Information (BOI) reporting. The now-overturned injunction originated from the U.S. District Court for Eastern Texas in Smith v. U.S. Department of the Treasury, is one of several legal challenges to the CTA, including SBAM’s own case.
Revised Deadline for BOI Reporting
FinCEN today revised the reporting requirements. For the vast majority of reporting companies, the new deadline to file an initial, updated, and/ or corrected BOI report is now March 21, 2025.
However, FinCEN noted the following in their published alert:
Notably, in keeping with Treasury’s commitment to reducing regulatory burden on businesses, during this 30-day period FinCEN 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 burden for lower-risk entities, including many U.S. small businesses.
What Does This Mean?
With this information from FinCEN and the outstanding Small Business Association of Michigan legal action, we recommend you wait a few weeks before filing to assess what will actually be required moving forward.
SBAM will continue to track developments and provide guidance as this issue evolves. If you have questions about your reporting obligations, consult with a legal or financial professional to ensure compliance.