
On February 18, 2025, the federal district court lifted the final nationwide injunction that had previously halted Beneficial Ownership Information (BOI) filing requirements.
Earlier, on February 6, 2025, FinCEN issued an alert stating that if the district court’s order were stayed—effectively reinstating the BOI Reporting Rule—it would extend the reporting deadline for all reporting companies by 30 days from the date the stay was granted. Additionally, in line with the Treasury Department’s commitment to reducing regulatory burdens on businesses, FinCEN would use that 30-day period to explore options for modifying deadlines or adjusting reporting requirements for lower-risk entities, such as many U.S. small businesses. Meanwhile, it would continue to prioritize reporting for entities that pose the most significant national security risks.
Current Reporting Status
For now, businesses have until March 21, 2025, to submit their BOI reports without facing late filing penalties. However, certain entities that were previously granted extensions beyond this date, particularly those affected by natural disasters, have specific deadlines:
Businesses impacted by Hurricanes Debby, Francine, Helene, and Milton now have until April 23, 2025, to submit their reports, per FinCEN's updated guidance.
Businesses affected by Hurricane Beryl, which initially had an extended deadline of February 6, 2025, must still meet the March 21 deadline.
Pending Legislation That May Affect Reporting Requirements
The U.S. House of Representatives recently passed H.R. 736, the Protect Small Businesses from Excessive Paperwork Act of 2025, which proposes postponing BOI reporting requirements for entities formed before January 1, 2024. The bill is now awaiting action in the Senate.
Key Changes Under the Proposed Legislation
This legislation would impact businesses that existed before 2024 by extending the deadline for BOI filings. Under the current rule, businesses formed before January 1, 2024, were required to submit their reports within two years of the regulation’s effective date. However, if H.R. 736 is enacted, these businesses would have until January 1, 2026, to submit their reports to the Financial Crimes Enforcement Network (FinCEN).
What This Means for Newly Formed Entities
For businesses established on or after January 1, 2024, reporting deadlines remain uncertain as FinCEN has yet to provide updated guidance. Previously, companies formed in 2024 were given a 90-day reporting window, while those established in 2025 and beyond had a 30-day requirement. These companies must now wait for further instructions from FinCEN regarding compliance timelines.
Stay Compliant—Schedule a Consultation
With BOI reporting deadlines shifting and legislative changes pending, it’s crucial for businesses to stay informed and compliant. Our team at TPSA CPAs can help you navigate the latest regulations and ensure your business meets its reporting obligations. Contact our office today to schedule a consultation and discuss your BOI filing requirements.