Beneficial Ownership Information (BOI) Timeline - Updated as of March 9, 2025
Current Status:
The Corporate Transparency Act's beneficial ownership reporting requirements are currently suspended for U.S. citizens and domestic reporting companies. The Treasury Department has indicated that it will not enforce these requirements or impose penalties on non-compliant businesses. Entities should monitor official communications from the Treasury Department and FinCEN for updates or changes to compliance requirements.
Recent Updates:
March 19, 2025 Announces NEW DEADLINE = March 21, 2025.
* March 2, 2025 - US Treasury Dept. announces The Corporate Transparency Act's beneficial ownership reporting requirements are currently suspended for U.S. citizens and domestic reporting companies.
- February 17, 2025 - Court Lifts BOI Reporting Injunction
A Texas federal district court lifted the injunction that had paused enforcement of the Corporate Transparency Act (CTA), effectively reinstating the beneficial ownership information (BOI) reporting requirement.
- February 18, 2025 - FinCEN has Announced New Deadline is March 21, 2025.
While FinCEN has not yet issued official guidance, prior statements indicate that they plan to set a new BOI filing deadline 30 days after the court ruling, suggesting that businesses may be required to file their reports by March 19, 2025.
- February 18, 2025 - Compliance Requirements Reinstituted
With the injunction lifted, reporting companies are once again required to submit their BOI information to FinCEN. However, the exact timeline and any modifications to the requirements remain pending.
- February 18, 2025 - FinCEN Considering Modifications to Reporting Requirements
During the 30-day extension period, FinCEN plans to explore changes to BOI reporting requirements. These modifications aim to reduce the burden on low-risk entities while prioritizing enforcement against entities posing national security risks.
- February 18, 2025 - Treasury Department Comments on Regulatory Burden
A U.S. Treasury official stated that the department remains committed to reducing regulatory burdens on businesses, aligning with FinCEN’s potential modifications to the reporting requirements.
- February 18, 2025 - Current Status for Businesses
As of today, small-business owners are required to file a BOI report. However, they should await official FinCEN guidance on the exact deadline and potential requirement changes.
Previous Updates:
- February 5, 2025 - Federal Government Requests to Lift Injunction
The federal government filed a motion in a Texas federal court requesting the lifting of the current injunction that prevented enforcement of the CTA’s beneficial ownership reporting requirements.
- January 13, 2025 - Extended Reporting Deadline Approaches
Although FinCEN had extended the reporting deadline to January 13, 2025, compliance remained voluntary due to ongoing legal challenges.
- December 27, 2024 - BOI Deadline Paused Again
The U.S. Fifth Circuit Court reinstated a nationwide injunction, halting the enforcement of the CTA’s reporting requirements.
- December 24, 2024 - FinCEN Extends Deadline
Following the Fifth Circuit’s decision, FinCEN announced an extension of the reporting deadline to January 13, 2025, to provide businesses more time to comply.
- December 23, 2024 - Fifth Circuit Grants Emergency Stay
The U.S. Fifth Circuit Court of Appeals granted the DOJ’s emergency motion for a stay of the District Court’s injunction, reinstating the CTA’s requirements with the original January 1, 2025, deadline.
- December 13, 2024 - DOJ Files Emergency Motion with the Fifth Circuit
The DOJ filed an emergency motion with the U.S. Fifth Circuit Court of Appeals after the District Court denied their previous stay request.
- December 12, 2024 - District Court Denies DOJ's Emergency Stay Request
Judge Amos L. Mazzant III denied the DOJ's motion for an emergency stay, emphasizing constitutional concerns regarding the CTA.
- December 10, 2024 - DOJ Requests Emergency Stay from District Court
The DOJ filed an emergency motion with Judge Mazzant seeking to lift the nationwide injunction, allowing the CTA’s enforcement to proceed.
- December 5, 2024 - DOJ Appeals the Nationwide Injunction
The DOJ appealed the preliminary injunction to the U.S. Fifth Circuit Court of Appeals, arguing the nationwide scope was overly broad.
- December 3, 2024 - Preliminary Injunction Granted
The U.S. District Court for the Eastern District of Texas issued a nationwide injunction against the CTA, halting the January 1, 2025, reporting deadline due to constitutional concerns.
