| Update Applicable to: | Effective Date |
| All Covered Entities | Extended Reporting: March 21, 2025 |
What happened?
The beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) was reinstated on February 18, 2025.
Overview:
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has reinstated the Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act (CTA). This follows a recent court decision that lifted a nationwide injunction.
- New Deadline: Most companies must file their initial, updated, or corrected BOI reports by March 21, 2025.
- Ongoing Litigation: There are ongoing legal challenges, but the reporting requirements are currently in effect.
- Potential Modifications: FinCEN plans to assess options to modify deadlines and reduce the reporting burden for lower-risk entities.
Companies should promptly comply with the reinstated BOI filing requirements and stay updated on any further regulatory changes from FinCEN.
Additional Details:
Reporting Deadlines:
- Formed prior to January 1, 2024: March 21, 2025.
- Formed in 2024: The later of (1) 90 days following the date of formation or (2) March 21, 2025.
- Formed on or after January 1, 2025: The later of (1) 30 days following the date of formation or (2) March 21, 2025.
Companies should promptly comply with the reinstated BOI filing requirements and stay updated on any further regulatory changes from FinCEN.
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