BOI reporting enforcement has been reinstated after a court decision lifted the temporary nationwide pause imposed by the Smith case. Reporting is once again mandatory. However, to assist reporting companies, FinCEN granted a 30-day filing extension from this decision date and will assess the need for further modified deadlines. The full notice can be found HERE.

Updated Deadlines 

• For the vast majority of reporting companies, the new deadline to file an initial, updated, and/or corrected BOI report is now March 21, 2025. FinCEN will provide an update before then of any further modification of this deadline, recognizing that reporting companies may need additional time to comply with their BOI reporting obligations once this update is provided. 
• Reporting companies that were previously given a reporting deadline later than the March 21, 2025, deadline must file their initial BOI report by that later deadline. For example, if a company’s reporting deadline is in April 2025 because it qualifies for certain disaster relief extensions, it should follow the April deadline, not the March deadline.
• Disaster relief is available for victims of Hurricane Milton, Hurricane Helene, Hurricane Debby, Hurricane Beryl, and Hurricane Francine. More information HERE. 
• Plaintiffs in National Small Business United v. Yellen are not currently required to report BOI information to FinCEN at this time.

Congressional Action

Additionally, the House unanimously passed the Protect Small Businesses from Excessive Paperwork Act of 2025 on Feb. 10, 2025, that would delay BOI reporting deadlines to Jan. 1, 2026. It currently sits with the Senate awaiting action.

General information on BOI reporting can be found HERE. We will continue to keep you updated as further developments occur. Please reach out with any questions or concerns.

Published: 02/25/2025

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