At Ivory Law Group, we’ve been closely tracking the changes to the Beneficial Ownership Information (BOI) reporting requirements. A federal court previously ruled against the implementation of the Corporate Transparency Act (CTA) which temporarily paused reporting requirements, but a new federal court ruling has lifted the stay. Businesses must now move quickly to meet the updated deadlines to avoid penalties.
New Deadline for Covered Entities: March 21, 2025
On February 18, 2025, the U.S. District Court for the Eastern District of Texas granted a stay order, reinstating the BOI reporting requirements. This means businesses that existed before January 1, 2024, now have until March 21, 2025, to file their initial reports with the Financial Crimes Enforcement Network (FinCEN).
Companies that have already begun preparing for the previous deadlines should ensure that their information is still accurate and complete. Businesses that had delayed filing due to the prior injunction must now take immediate action to meet the new deadline.
New Deadline for Newly-Created Entities: 30-Day Requirement
For businesses formed or registered on or after February 18, 2025, the clock is already ticking. These entities must submit their BOI report within 30 days of their formation or registration. This requirement significantly shortens the previous 90-day window that had applied to companies created in 2024.
Additionally, any reporting companies that were granted extensions due to disaster relief must adhere to the latest deadlines provided by FinCEN unless they were granted an extension that is later than the new deadlines.
What is a Beneficial Owner and What Information is Required?
The CTA defines a beneficial owner as an individual who directly or indirectly exercises substantial control over a reporting company or owns at least 25% of the entity’s ownership interests. This applies to corporations, limited liability companies (LLCs), and certain other entities registered in the U.S.
Reporting companies must submit the following information about beneficial owners:
- Full legal name
- Date of birth
- Residential address
- Identifying number from an acceptable form of identification (passport, driver’s license, etc.)
- A copy of the identification document
In addition, reporting companies must provide key company details, including legal name, any trade names, principal place of business, jurisdiction of formation, and taxpayer identification number.
Make Sure Your Organization is in Compliance Now
With the latest court ruling, businesses and their in-house legal teams must act quickly to meet the reinstated BOI reporting deadlines. Failing to file on time could lead to significant penalties, but there is still time to take the necessary steps. If you’re unsure what information to report or need assistance gathering and filing the required details, Ivory Law Group can help. Even if you’re unable to meet the deadline, we can guide you through the process and help mitigate potential risks. Given the ongoing legal challenges, these deadlines may still change, so staying informed and prepared is essential. You can stay in touch by getting in touch with Ivory, signing up for our newsletter, or tuning into the latest episodes of the Ivory GC podcast.
*Disclaimer: The content provided in this blog is for informational purposes only and does not constitute legal advice. Reading this blog does not create an attorney-client relationship with Ivory Law Group or any of its attorneys. For legal advice, please consult with a qualified attorney directly.
Ivory Law Group
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