For months, businesses have been caught in a regulatory whiplash over Beneficial Ownership Information (BOI) reporting under the Corporate Transparency Act (CTA). First, it was required. Then, a federal court put it on hold. Now, thanks to a February 18, 2025, court ruling, BOI reporting is back in full force—and this time, it’s unlikely to disappear.
If you’ve been waiting to see how this plays out, stop waiting and start filing.
New Deadline: March 21, 2025
To give businesses more time to comply, the Financial Crimes Enforcement Network (FinCEN) has extended the BOI filing deadline by 30 days—moving it to March 21, 2025 for most companies. This is your last chance to get ahead of potential penalties.
Who Needs to File?
Most U.S. companies, including LLCs, corporations, and foreign entities registered in the U.S., must report who really owns or controls them. Some exemptions apply (e.g., publicly traded companies, large operating businesses, banks), but for most small and mid-sized businesses, compliance is mandatory.
Control Persons
A control person in a small business or real estate entity isn’t just an owner—it’s anyone who has substantial influence over key decisions. This could include a CEO, CFO, manager, general partner, trustee, or even a key advisor who directs major business operations. For real estate owners, this might mean property managers with decision-making authority, managing members of an LLC, or someone controlling leasing, financing, or asset sales. Even if these individuals own zero equity, they must be reported in the BOI filing if they exercise significant control over the entity. Skipping control persons could mean noncompliance—so make sure you report everyone who fits the criteria.
BOI Reporting Isn’t Going Away This Time
The government has made it clear: they’re reworking the BOI reporting rules, not eliminating them. FinCEN is planning adjustments to reduce the burden on low-risk businesses, but those tweaks won’t change the fact that BOI reporting is here to stay.
What You Need to Do Now
If you haven’t filed yet, don’t wait—use the extra 30 days to get compliant.
File your BOI report online for free at boiefiling.fincen.gov.
If you were hoping for another delay, don’t count on it. The legal battles are winding down, and FinCEN has every intention of enforcing this rule.
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