BOI Reporting is Back on with January 13 Deadline

Share this post
CTA requires BOI report

Court Reinstates Corporate Transparency Act BOI Reporting

FinCEN Extends Filing Deadlines to January 13, 2025

On December 23, 2024, the federal Court of Appeals decided most reporting companies are once again required to file Beneficial Ownership Information (BOI) with Financial Crimes Enforcement Network (FinCEN). The Department of the Treasury, that oversees FinCEN, recognizes that reporting companies may need additional time to comply given the period when the preliminary injunction had been in effect. The new deadline to submit BOI reports is as follows:

The deadline for most reporting companies to file BOI reports was extended to Jan. 13, 2025.

  • Reporting companies that were created or registered prior to January 1, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN. (These companies would otherwise have been required to report by January 1, 2025.)
  • Reporting companies created or registered in the United States on or after September 4, 2024, that had a filing deadline between December 3, 2024 and December 23, 2024 have until January 13, 2025 to file their initial beneficial ownership information reports with FinCEN.
  • Reporting companies created or registered in the United States on or after December 3, 2024, and on or before December 23, 2024 have an additional 21 days from their original filing deadline to file their initial beneficial ownership information reports with FinCEN.
  • Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond January 13, 2025. These companies should abide by whichever deadline falls later.

Reporting companies that are created or registered in the United States on or after January 1, 2025 have 30 days to file their initial beneficial ownership information reports with FinCEN after receiving actual or public notice that their creation or registration is effective. The case is still being litigated. But in its order, the Fifth Circuit said that “the government has made a strong showing that it is likely to succeed on the merits in defending CTA’s constitutionality.”

A one-year delay in BOI reporting requirements was included in a proposed spending bill in the House of Representatives last week. But the version of the bill passed by Congress late Friday, avoiding a government shutdown, did not include any BOI deadline provisions.

Under the CTA, P.L. 116-283, which Congress passed in 2021 as an anti-money-laundering initiative, reporting companies must disclose the identity of and information about beneficial owners of the entities. For new entities incorporated after Jan. 1, 2024, reporting companies must also disclose the identity of “applicants”- defined as any individual who files an application to form a corporation, limited liability company, or other similar entity.

The topic of Beneficial Ownership Reporting has had lots of changes over the past year. Our goal is to keep you abreast of the important notices to ensure your business is compliant. Contact us at info@madonia.com or (312) 578-9300 with questions, concerns or to file your BOI report.