BOI Reporting is Back: New Filing Deadline

Our Impact Team
Dec 27, 2024
2 min read

On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit lifted a nationwide injunction that temporarily halted the enforcement of the Corporate Transparency Act (CTA) and its Beneficial Ownership Information (BOI) reporting requirements.

This decision reinstates the obligation for certain entities to file BOI reports with the Financial Crimes Enforcement Network (FinCEN).

Source Link: https://www.fincen.gov/boi

Key Updates on Beneficial Ownership Reporting:

Extended Deadlines for Existing Companies:
- Companies established before January 1, 2024: The initial deadline for these companies to submit their beneficial ownership information has been extended from January 1, 2025, to January 13, 2025. This extension provides additional preparation time that may have been needed due to a previously placed preliminary injunction.
Adjusted Deadlines for Newly Registered Companies:
- Companies registered between September 4, 2024, and December 23, 2024: Entities falling within this registration period that faced filing deadlines from December 3, 2024, to December 23, 2024, now have until January 13, 2025, to comply with the filing requirements.
- Companies registered between December 3, 2024, and December 23, 2024: These companies will benefit from an additional 21 days beyond their original filing deadlines to submit their beneficial ownership information.
Guidance for Companies Registered Post-2024:
- Companies registered on or after January 1, 2025: These entities must file their initial beneficial ownership reports within 30 days of receiving notice (actual or public) that their creation or registration is effective.
Special Considerations:
- Disaster Relief: Companies qualifying for disaster relief may have further extended deadlines, which should be observed as per the later of the applicable dates.
- Exemptions: Specific plaintiffs such as Isaac Winkles, and entities related to the National Small Business Association as of March 1, 2024, are currently exempt from reporting their beneficial ownership information due to ongoing litigation.

Final Thoughts: The extension of deadlines and reinstatement of reporting requirements signify a critical period for compliance among U.S. businesses. Companies are advised to closely monitor updates related to the CTA and consult with legal counsel to ensure compliance with the new guidelines. The evolving legal environment underscores the importance of staying informed and prepared to meet federal regulations.

How We Can Help: Our business is here to guide you through the complexities of regulatory compliance, including navigating the current uncertainties surrounding the Corporate Transparency Act (CTA). Staying informed and proactive can make all the difference. Contact our Impact Team to get personalized assistance tailored to your specific needs.

Schedule A Free Consultation Now