As a trusted advisory firm, we understand the importance of staying ahead of regulatory changes that impact business operations. One of the most significant shifts in recent years is the Beneficial Ownership Information (BOI) filing requirement under the Corporate Transparency Act (CTA).
While compliance with regulatory filings may not always be top-of-mind for business owners, it is essential to understand how these changes affect your company and what steps you should take to remain compliant. Recent court rulings, deadline extensions, and FinCEN’s temporary enforcement relief have created uncertainty, but we recommend taking a proactive approach rather than waiting until penalties are reinstated.
In this update, we break down the latest BOI filing changes, key deadlines, and what your business should do next.
Key Legal and Court Updates
The Corporate Transparency Act (CTA), which mandates BOI reporting, has faced multiple legal challenges. Here’s what you need to know:
- February 18, 2025: A federal court reinstated the requirement for businesses to submit BOI filings, reversing a prior injunction that had temporarily paused enforcement.
- Upcoming Court Review: The 5th Circuit Court of Appeals is scheduled to hear additional arguments on March 25, 2025. While this could influence future enforcement policies, companies should assume that compliance remains necessary.
At this time, businesses are required to file unless further legal action changes this obligation.
Updated Deadlines & Enforcement Policies
Extended Filing Deadline
- The new BOI filing deadline is March 21, 2025, for most businesses.
- Companies formed after January 1, 2025, may have a different reporting timeline.
Temporary Relief from Penalties
On February 27, 2025, FinCEN announced it will not impose penalties for businesses that fail to meet the BOI filing deadline until a new interim rule is issued. This rule is expected by March 21, 2025.
While this provides temporary relief, business owners should not assume non-compliance will be overlooked indefinitely. Once the rule is in place, enforcement could resume quickly, including potential fines or penalties.
What This Means for Your Business
As an advisory firm, we recommend that companies use this grace period wisely rather than waiting until deadlines are enforced with penalties.
Many business owners assume that regulatory filings like BOI reporting don’t apply to them—but the reality is that most corporations and LLCs must file, unless they meet specific exemption criteria.
Here’s how to determine your next steps:
Step-by-Step Guide to BOI Compliance
Step 1: Determine Whether Your Business Must File
Most corporations, LLCs, and similar entities must comply. However, certain businesses are exempt, including:
✔ Publicly traded companies
✔ Banks and financial institutions
✔ Tax-exempt nonprofits
✔ Large operating companies with 20+ employees and $5M+ in revenue
If you are unsure whether your business qualifies for an exemption, we advise reviewing FinCEN’s official exemption criteria on FinCEN’s website.
Step 2: Gather the Required Information
To complete the filing, businesses must submit information on all beneficial owners—individuals who own or control at least 25% of the company or exercise substantial influence.
Information required includes:
✔ Full legal name
✔ Date of birth
✔ Residential address
✔ A government-issued ID (e.g., passport or driver’s license)
✔ An image of the ID document
Step 3: Consider Applying for a FinCEN Identifier
If privacy is a concern, beneficial owners can apply for a FinCEN Identifier, which allows them to submit a unique number instead of personal details when filing BOI reports.
Step 4: Submit Your BOI Report
BOI filings must be submitted electronically via FinCEN’s online portal: FinCEN’s BOI Reporting Page
Filing Options:
✔ Online Submission: Enter details directly into FinCEN’s portal.
✔ PDF Upload: Download, complete, and submit the official BOI form.
It’s critical to review all information for accuracy before submission, as errors could lead to compliance issues later.
Step 5: Stay Informed & Prepare for Future Changes
With ongoing legal challenges, we recommend that business owners:
- Monitor updates from FinCEN and regulatory sources.
- Seek professional guidance if unsure about their compliance obligations.
- File sooner rather than later to avoid potential penalties once enforcement begins.
What We Advise Business Owners to Do Now
Given FinCEN’s temporary pause on penalties, some businesses may be tempted to delay filing. However, we do not recommend this approach.
✔ Understand your obligations – Many businesses wrongly assume they are exempt.
✔ Prepare your documentation – Gathering necessary details now avoids last-minute issues.
✔ File before March 21, 2025 – Compliance is required, and delays could result in penalties.
✔ Monitor legal developments – Future court rulings could impact enforcement, but compliance remains mandatory for now.
While we are not regulatory compliance specialists, we advise all businesses to take proactive steps to ensure they meet their obligations under the law.
Final Thoughts from a Business Advisory Perspective
As advisors, we understand that regulatory compliance can feel like just another bureaucratic task. However, BOI filing requirements are not optional, and businesses that fail to comply could face penalties in the future.
We encourage business owners to use this temporary enforcement pause wisely—prepare now, ensure your filings are correct, and avoid unnecessary risks.
If you need assistance with business planning, compliance strategy, or operational adjustments, our team is here to help.
For more details on BOI requirements, visit: FinCEN’s BOI Reporting Page
If you have questions about how this impacts your business, let’s discuss how we can help you stay ahead of regulatory changes and focus on what matters most—growing your business.
Article by:
Kyle Kennedy
Tax Advisor
