The new deadline to comply with the Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act is March 21, 2025, as the nationwide injunctions preventing enforcement by the Financial Crimes Enforcement Network (FinCEN) have been lifted¹. Most entities (corporations, limited liability companies, and limited partnerships) have until March 21, 2025, to file initial, corrected, and updated BOI reports. Newly formed entities will have 30 days from the date of formation to file their initial BOI reports. Reporting companies that previously submitted BOI reports do not need to take any further action unless there has been a change to the initially reported information.

A “reporting company” is a domestic entity created by filing with the Secretary of State of any state or a foreign entity registered to do business with the Secretary of State of any state, subject to 23 exemptions. Reporting companies must report the full legal name, birthdate, residential address, and a unique identifying number from a passport or driver’s license (along with a copy of the passport or driver’s license) for any person who directly or indirectly has at least a 25% ownership interest in the reporting company or exercises substantial control over the reporting company. Reporting companies can complete the BOI reports directly through FinCEN’s website.

FinCEN has also announced its intention to revise the BOI reporting rule to reduce the burden on “lower-risk entities.²” However, FinCEN has not provided details on the nature of the proposed revisions.

The Corporate Transparency Act is still being challenged in several cases across the country. On February 10, 2025, the U.S. House of Representatives unanimously passed a bill that would extend the filing deadline for reporting companies formed before January 1, 2024, by one year, to January 1, 2026³. The bill has been referred to the Senate Committee on Banking, Housing, and Urban Affairs, but no action has been taken.

We continue to monitor ongoing legal challenges and proposed legislation related to the Corporate Transparency Act. 

¹ Smith, et al. v. U.S. Department of the Treasury

² https://www.fincen.gov/sites/default/files/shared/FinCEN-BOI-Notice-Deadline-Extension-508FINAL.pdf

³ H.R.736 - Protect Small Businesses from Excessive Paperwork Act of 2025