Corporate Transparency Act Reporting Requirements Back in Effect with Extended Reporting Deadline: March 21, 2025

*** UPDATE ***

Following the February 18, 2025, decision by the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336, the Financial Crimes Enforcement Network (FinCEN) has announced that beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act are back in effect, with a new deadline of March 21, 2025 for most companies.

FinCEN has also announced that it will assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks. FinCEN intends to initiate a process this year to revise the BOI reporting rule to reduce burden for lower-risk entities, including many U.S. small businesses.

What is the Beneficial Ownership Information (BOI) Report?

As of January 1, 2024, the bipartisan Corporate Transparency Act, enacted in 2021 to curb illicit finance, requires many companies doing business in the United States to report information to the Financial Crimes Enforcement Network (FinCEN) about the individuals who ultimately own or control them. FinCEN is a bureau of the U.S. Treasury Department.

• Filing is quick, secure, and FREE, and most companies should be able to report without the help of an accountant or lawyer.
• For companies with simple ownership structures, filing may take less than 20 minutes.
• Unless a company needs to update or correct information, it is a one-time filing requirement.

Who Must Complete the BOI Report?

Companies that are required to comply (“reporting companies”) must file their initial reports by the following deadlines:

• Existing companies: Reporting companies created or registered to do business in the United States before January 1, 2024 must file by the new extended date of March 21, 2025.
• Newly created or registered companies: Reporting companies created or registered to do business in the United States have 30 calendar days to file after receiving actual or public notice that their company’s creation or registration is effective.

What happens if a reporting company fails to file?

A person who willfully violates beneficial ownership reporting requirements may be subject to civil penalties of up to $591 for each day that the violation continues, as well as criminal penalties of up to two years imprisonment and a fine of up to $10,000. Potential violations include willfully failing to file a beneficial ownership information report, willfully filing false beneficial ownership information, or willfully failing to correct or update previously reported beneficial ownership information.

Let the SBDC assist you in filing your Beneficial Owner Information (BOI) Report before the deadline at no cost to you!

At NJSBDC at Brookdale Community College, we are dedicated to empowering small business owners through every step of their journey, especially when fulfilling compliance requirements like the mandatory Business Ownership Information (BOI) Report. We provide personalized guidance tailored to your unique business needs. Our resources are designed to ensure that you meet compliance standards and thrive in a supportive and inclusive environment. We believe that every entrepreneur deserves the tools and knowledge to succeed, and we are committed to walking alongside you as you tackle these essential requirements.