BOI Reporting Deadlines: Key Dates for Compliance

Recent Developments and Extended Deadlines

On December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit granted a stay of the nationwide preliminary injunction that previously halted CTA enforcement. As a result, most reporting companies are again obligated to file BOI reports with FinCEN. Recognizing the interruption caused by the injunction, the Department of the Treasury has extended certain deadlines:

• Entities Formed Before January 1, 2024: **New Deadline**: January 13, 2025. (These companies would otherwise have been required to file by January 1, 2025.)
• Entities Created or Registered on or After September 4, 2024 that had a filing deadline between December 3 and December 23, 2024 also have until January 13, 2025 to file their initial BOI reports.
• Entities Created or Registered between December 3 and December 23, 2024 have an additional 21 days from their original filing deadline to submit their initial BOI reports.
• Disaster Relief Extensions: Companies qualifying for disaster relief may have a later filing date than January 13, 2025. Such entities should follow whichever deadline occurs last.
• Entities Created on or After January 1, 2025: Must file their BOI reports within 30 days of receiving public or actual notice that their creation or registration is effective.

Certain plaintiffs in pending court cases—including members of the National Small Business Association (as of March 1, 2024) and others—remain exempt from filing obligations for now. For more details on these legal challenges and who they affect, please consult the official FinCEN updates or speak with a qualified advisor.

Companies Formed Before January 1, 2024

Under the revised timeline, companies formed prior to January 1, 2024 now have until January 13, 2025 to file their Beneficial Ownership Information (BOI) reports. Previously, these businesses would have been required to file by January 1, 2025. The extension aims to give these entities extra time to gather ownership data and ensure an accurate, on-time filing.

• Required Information: Full names, addresses, dates of birth, and identification numbers (EIN, SSN, or TIN) for each beneficial owner.
• BOIR E-FILE System: Use our online E-File System for submitting BOI reports. For detailed steps, refer to our guide on The BOIR Filing Process: A Complete Guide for 2024.

Companies Formed On or After January 1, 2024

For companies created on or after January 1, 2024, earlier guidelines indicated a 90-day window to file after formation. While this remains generally accurate, certain recent changes apply based on when the entity was created and whether it was impacted by the previously effective nationwide injunction:

• Entities Formed Sept. 4–Dec. 3, 2024: If you had a deadline falling between December 3 and December 23, 2024, you now have until January 13, 2025 to file your initial BOI reports.
• Entities Formed Dec. 3–Dec. 23, 2024: You have an extra 21 days beyond your original filing deadline to submit your BOI reports.
• Entities Formed On or After Jan. 1, 2025: Once their creation or registration takes effect, these companies must file within 30 days of receiving either public or actual notice of effectiveness.

Ongoing Reporting Obligations

Any changes in a company’s beneficial ownershipmust be reported to FinCEN within 30 days of the change. These updates ensure that FinCEN’s records accurately reflect ownership structures.

• Compliance Importance: Promptly update ownership records to avoid fines and remain compliant.
• Continuous Monitoring: Ensure accurate and up-to-date information by establishing a compliance process for ongoing reporting obligations.