BOI Reporting Reinstated: FinCEN Extends Most Deadlines to March 21, 2025

The U.S. District Court for the Eastern District of Texas has reinstated Beneficial Ownership Information (BOI) reporting requirements. This decision follows the court’s move to lift the preliminary injunction previously issued in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.). As a result, the Financial Crimes Enforcement Network (FinCEN) has confirmed that most reporting companies must now file their BOI reports by March 21, 2025.

This decision comes after the U.S. Department of Justice appealed on behalf of the Treasury Department, challenging the court’s previous stay and requesting a pause on its order while the appeal is being considered. On February 18, the court agreed to extend the pause on the rule until the appeal process is finalized.

New Reporting Deadlines

Most reporting companies must submit an initial, updated, or corrected BOI report by March 21, 2025. The FinCEN alert acknowledged that reporting companies “may need additional time to comply with their BOI reporting obligations,” prompting the 30-day extension for most entities from the February 18 court decision. FinCEN will assess further deadline modifications during this period, prioritizing businesses that pose the most significant national security risks.

The March 21, 2025, deadline does not apply to:

• Reporting companies previously granted a deadline later than March 21, 2025, should file their BOI by the later deadline. For example, those impacted by the hurricane disaster relief extension.

• Plaintiffs in National Small Business United v. Yellen, No. 522-cv-01448 (N.D.), including companies where Isaac Winkles is a beneficial owner or applicant, as well as the National Small Business Association (NSBA) and its members are currently exempt from reporting.

Next Steps for Reporting Companies

All entities subject to BOI reporting must act promptly to file by the deadline. Reporting companies that do not file by the deadline may be subject to substantial fines of up to $10,000.

Future of BOI Reporting

Companies should stay informed about potential court rulings that may impact reporting requirements. Additionally, FinCEN has announced plans to revise BOI reporting rules in 2024 to reduce the regulatory burden on lower-risk entities. As these regulatory adjustments take shape, businesses should monitor updates to ensure compliance with evolving requirements. Stay tuned for updates as we continue to monitor FinCEN updates.

If you have any questions or need assistance with the BOI reporting requirements, please feel free to contact your BGM relationship manager. They are available to provide guidance and help ensure you stay in compliance with the latest regulations. We’re here to support you through the process.