BOI Filing Requirements Paused (Again) — Here’s What You Need to Know

It’s off, it’s on, now it’s back off again.

Where We Stand Now

Reporting companies are not currently required to file BOI reports and will not face penalties for failing to file while the injunction is in effect. However, FinCEN is still accepting voluntary submissions for those who wish to file.

The Holiday Whirlwind of BOI Reporting Developments

While many of you were out for the holidays, significant developments have occurred regarding the Corporate Transparency Act (CTA) compliance requirements. Here’s a brief recap of what has happened:

• Dec. 3, 2024: A federal court in Texas issued an injunction, halting FinCEN’s enforcement of Beneficial Ownership Information (BOI) filing requirements.
• Dec. 23, 2024: The Fifth Circuit Court of Appeals temporarily lifted the injunction, reinstating the BOI reporting requirement. In response, FinCEN extended the filing deadline for companies formed before 2024 to January 13, 2025.
• Dec. 26, 2024: The court reinstated the injunction, blocking enforcement of the BOI filing requirements until further notice.

For those who have been following our updates throughout the past year, we’ve published a series of articles that break down the various aspects of BOI reporting, such as understanding the basics of the Corporate Transparency Act, the benefits of using a FinCEN Identifier, and the latest guidance on what to include in your filings.

Click here to read more and stay informed.

We Are Here to Make the Complex Simple

We will continue to monitor this evolving situation and provide timely updates. If you have any questions or concerns, feel free to reach out.