BOI Reporting Update: Court Reinstates Requirements, FinCEN Extends Deadline to March 21, 2025

On February 18, 2025, the U.S. District Court for the Eastern District of Texas reinstated the controversial BOI reporting mandate. Fortunately, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) granted extra time to file, extending the deadline for beneficial ownership information (BOI) reporting under the Corporate Transparency Act (CTA). Most reporting companies now have until March 21, 2025 to submit their initial, updated, or corrected BOI reports. FinCEN is also reviewing potential revisions to the reporting rule to ease the regulatory burden on small businesses and lower-risk entities.

Key Updates on BOI Reporting Deadlines

• New Deadline. Most reporting companies must file their BOI reports by March 21, 2025. FinCEN will issue an update before this date if additional modifications are made.
• Exceptions for Later Deadlines. Companies with later reporting deadlines due to disaster relief or other extensions should follow their originally assigned deadlines.
• Exempt Entities. Certain plaintiffs in National Small Business United v. Yellen are not required to report BOI at this time.

Background on the Court Decision

As clients are aware, ongoing legal challenges related to BOI reporting requirements created much uncertainty regarding compliance deadlines and enforcement. AAFCPAs’ has been following these developments closely and providing updates as appropriate. Read AAFCPAs’ previous blog, which outlines court rulings, updated deadlines, and guidance from FinCEN.

Compliance and Filing Information

Reporting companies may submit BOI reports free of charge through FinCEN’s E-Filing system. More information on compliance and reporting obligations is available at fincen.gov/boi.

Businesses subject to BOI reporting requirements should review their obligations and ensure timely compliance. FinCEN’s planned revisions to the reporting rule may offer additional relief for small businesses. But until further guidance is issued, AAFCPAs advises that clients follow ongoing updates on our blog and prepare to meet the March 21, 2025 deadline. Those with unique circumstances, such as disaster relief extensions, should verify their specific filing deadlines.

How We Help

AAFCPAs’ Tax Compliance and Advisory practice provides businesses with the expertise needed to navigate complex regulatory requirements including BOI reporting compliance. Our multidisciplinary team of CPAs, tax consulting attorneys, and financial professionals offers tailored guidance to help businesses meet compliance requirements efficiently and in alignment with their broader financial and operational goals. We work closely with clients to identify beneficial owners, ensure accurate reporting, and integrate compliance strategies into overall tax planning. By taking a proactive approach, we help clients mitigate risks, streamline processes, and stay ahead of regulatory changes.

If you have questions, please contact Erica Nadeau, CPA, MST, Tax Partner at 774.512.4111 or enadeau@aafcpa.com, Stacie Amaral Field, CPA, MBA, Tax Partner at 774.512.4103 or sfield@aafcpa.com—or your AAFCPAs Partner.