As we continue to monitor the Beneficial Ownership Information (BOI) reporting situation for business owners as part of the Corporate Transparency Act (CTA), here are the most recent updates coming from the U.S. Treasury Department.
The Financial Crimes Enforcement Network (FinCEN) took a step back on February 27, 2025. It issued a release stating it would not issue fines, penalties or take any other enforcement action against companies based on any failure to file or update BOI reports.
See the full announcement here.
This announcement comes shortly after FinCEN announced a new deadline for BOI reporting of March 21, 2025. As part of its “commitment to reducing regulatory burden on businesses,” FinCEN is exploring an interim final rule that extends the deadline and follows the intended goal of the CTA.
FinCEN also stated that it is soliciting public comment on revisions to the existing BOI reporting requirements. The March 21, 2025, deadline will be used for FinCEN to issue the interim final rule, with final rulemaking happening later in 2025, according to the February 27, 2025, release.
Current Rulemaking on BOI
As we reported in previous articles, companies need to comply with the BOI reporting requirement – which was enacted as part of the Corporate Transparency Act in an effort to reduce money laundering – if they have fewer than 20 employees and take in less than $5 million in gross receipts annually. Hence, the BOI reporting requirement falls mainly on small businesses. However, 23 types of entities are exempt from the BOI reporting requirement.
Ongoing federal district court cases have prevented enforcement of BOI reporting until the U.S. Supreme Court called to remove a national injunction and a U.S. District Court of Appeals for the Fifth Circuit deferred to that ruling.
However, at least three bills have been introduced in Congress to either delay the BOI reporting deadline or repeal the CTA altogether. One bill has passed the House, and would simply delay reporting until January 1, 2026.
For companies subject to BOI reporting, there is no enforcement of fines or penalties at this time. To see the requirements for BOI reporting, visit the official FinCEN site. If you have already submitted BOI, you do not need to do anything further.
NOTE: Fraudulent websites for BOI reporting have been set up to collect sensitive business information and money. They are typically listed as “Sponsored” sites in search results. FinCEN does not:
- Require a fee for BOI reporting
- Send correspondence by email with links or QR codes
- Request fees or sensitive information by mail
Do not respond to these requests or share your personal information.
If you are unsure of correspondence that you receive from federal or state agencies for your small business, go to the official websites and use proper channels and phone numbers to learn more before clicking on anything or responding. If you have questions, contact us at G.T. Reilly.
