Keeping Track of BOI Reporting Deadlines

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Nothing Due at This Time Despite Supreme Court Ruling

Running a small business comes with a seemingly endless list of tasks, and keeping up with new regulations can feel overwhelming. Beneficial Ownership Information (BOI) reporting, a requirement for most small businesses in the U.S. under the Corporate Transparency Act (CTA), might seem like just another burden. Add to the mix the on-again/off-again status of the requirement and it becomes quite hard not to tune out.

If you heard recently that the Supreme Court ruled in favor of reporting, you would be correct but still not need to submit a BOI report. On January 23, 2025, the Supreme Court granted the government’s motion to stay a nationwide injunction issued by a federal judge in Texas (Texas Top Cop Shop, Inc. v. McHenry—formerly, Texas Top Cop Shop v. Garland).

Even though the Supreme Court overturned the order from a Texas appeals court in the case of Texas Top Cop Shop v. Garland, there is a separate nationwide order issued by a different Texas judge that remains in the case of Smith v. U.S. Department of the Treasury. Because of that, the Treasury Department is currently not requiring reporting companies to provide their BOI details to FINCEN. The FINCEN BOI website has a red banner stating that currently, reporting companies are not required to file BOI reports but may voluntarily submit them.

We understand there is much confusion around if and when you need to file a BOI report currently. The good news is that nothing is due at this time, so you aren’t facing a deadline. Yet keep in mind that future rulings may change this situation. We hope to keep our clients informed in a clear voice and timely manner. If you have questions regarding BOI or other issues, please contact us at (312) 578-9300 or info@madonia.com.