BOI Reporting Requirements Reinstated–New Deadline Set

If you’ve been watching the legal ping-pong match over Beneficial Ownership Information (BOI) reporting, here’s the latest serve: the federal Court of Appeals has reinstated the requirement for companies to file their Beneficial Ownership Information (BOI) reports with FinCEN, reversing the recent preliminary injunction.

This decision impacts businesses subject to the Corporate Transparency Act (CTA) and establishes new compliance deadlines to account for the paused enforcement period.

Here’s what you need to know about the new reporting deadlines and how they may affect your business.

What Has Changed?

As of December 23, 2024, reporting companies are now required to file BOI reports with FinCEN. However, recognizing the confusion and potential delays caused by the earlier injunction, the Department of the Treasury has extended the original reporting deadlines, giving businesses additional time to comply.

Revised Filing Deadlines

The following revised deadlines apply depending on the date your company was created or registered:

Companies Created or Registered Before January 1, 2024:

These companies now have until January 13, 2025, to file their initial BOI reports with FinCEN. This is an extension from the original deadline of January 1, 2025.

Companies Created or Registered Between September 4, 2024, and December 23, 2024:

These businesses were originally required to file by January 13, 2025, and this deadline remains unchanged.

Companies Created or Registered Between December 3, 2024, and December 23, 2024:

Companies in this group receive an additional 21 days beyond their original filing deadline to submit their BOI reports.

Companies Created or Registered After January 1, 2025:

Newly created or registered companies must file their BOI reports within 30 days of creation or registration.

Companies Qualifying for Disaster Relief:

Companies in disaster-affected areas may qualify for extended deadlines. These companies should follow the longer of the established deadlines.

Special Exemptions

Certain applicants and organizations involved in litigation surrounding the CTA may not currently be required to file BOI reports. Specifically, businesses associated with the plaintiffs in National Small Business United v. Yellen are exempt from BOI filing requirements at this time. If you believe your business falls under this exemption, consult a legal advisor for clarity.

What Is Required in a BOI Report?

A BOI report must include identifying information about the company's beneficial owners and, in some cases, its applicants. This information ensures compliance with the CTA's transparency requirements aimed at combating financial crimes.

How to Prepare for the January 13, 2025 Deadline

With the reinstatement of the BOI filing requirement, it’s essential to take immediate steps to prepare your submission. Here’s what you can do now:

Confirm Your Company’s Filing Deadline: Identify your reporting category to determine your exact deadline under the revised schedule.
Gather Required Information: Ensure all necessary details about beneficial owners and applicants are ready for submission.
Seek Professional Assistance: If you need help preparing or filing your report, contact compliance professionals who specialize in CTA requirements.

Need Help? We've Got You. 

We understand the annoyance of BOI compliance which is why our team is here to assist you every step of the way. Contact us at BOI@patrickaccounting.com or cheria@patrickaccounting.com for guidance on filing your report or understanding your company’s specific obligations.

The Ball's In Your Court

BOI reporting is back, and it’s your turn to serve. You’ve got the time and the resources—use them wisely.

The reinstatement of the BOI reporting requirement underscores the importance of compliance for businesses across the country. With the new deadline of January 13, 2025, businesses now have additional time to meet their obligations. Stay proactive, stay informed, and let us help ensure you remain compliant with these federal requirements.

For more updates, keep an eye on our blog or reach out to our team directly!

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