Small Businesses Must File BOIR Reports by March 21, 2025
The nationwide pause on filing Beneficial Ownership Information Reports under the Corporate Transparency Act has been lifted by a Federal court in Texas. Companies that are required to file reports under this law now have until March 21, 2025.
The case will continue through the appeal process, and mandatory filings requirements have resumed.
In 2021, the Corporate Transparency Act was passed, requiring most corporations and LLCs to file information about their “beneficial owners” with the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of Treasury.
Domestic “Reporting Companies” who will be required to file reports are generally:
• corporations,
• LLCs and
• other entities formed by filing documents with a state Secretary of State or a tribal equivalent.
There are exemptions for SEC-reporting companies, regulated financial service companies, tax-exempt companies, insurance companies, accountants, large companies (with at least 20 US employees and at least $5 million in gross revenues) and other kinds of companies that are already required to report similar information. Certain inactive companies are exempt as well.
Updated Deadlines
For most reporting companies, the new deadline to file an initial, updated, and/ or corrected BOI report is now March 21, 2025. FinCEN will provide an update before then of any further modification of this deadline, recognizing that reporting companies may need additional time to comply with their BOI reporting obligations once this update is provided.
Reporting companies that were previously given a reporting deadline later than the March 21, 2025 deadline must file their initial BOI report by that later deadline. For example, if a company’s reporting deadline is in April 2025 because it qualifies for certain disaster relief extensions, it should follow the April deadline, not the March deadline.
Reporting companies can report their beneficial ownership information directly to FinCEN, free of charge, using FinCEN’s E-Filing system available at https://boiefiling.fincen.gov. More information is available at fincen.gov/boi.
Legal Direction is also able to assist reporting companies for a fee.
More information on the court cases and status of the Act can be found here.
