March 2nd Update: Treasury Department Announces It Will Not Enforce Non-Compliance of BOI Reporting Requirement
Update: The Corporate Transparency Act and its BOI reporting requirements are currently under litigation. Please refer to our most recent post for the latest developments.
The Treasury Department announced on March 2, that it will not enforce any penalties or fines related to the beneficial ownership information (BOI) reporting rule under the Corporate Transparency Act, both under the current deadlines and after upcoming rule changes. Additionally, the Treasury plans to issue a proposed rulemaking to limit the rule’s scope to foreign reporting companies only.
If all the recent news around the CTA and BOI sounds confusing, it’s because it is. If you are a small-business owner affected by the Corporate Transparency Act, here is what you need to know: As of March 2, BOI Reporting Requirement is still in place, however, the Treasury says it will not enforce penalties for non-compliance. Stay tuned to our updates, as we will be watching for changes in the future.
Recap of the BOI Legal Tug-of-War
January 1, 2024: The Corporate Transparency Act went into effect. Businesses formed before January 1, 2024, were required to file BOI reports by January 1, 2025. Newly formed businesses were given 90 days to file, with that window shrinking to 30 days starting in 2025.
March 2024: An Alabama court granted an injunction, but it applied only to a specific group including the National Small Business Association and its members.
December 3, 2024: A Texas federal court issued a nationwide injunction, temporarily blocking the law for all affected businesses just weeks before the original January 1, 2025, deadline.
December 23, 2024: A Fifth Circuit motions panel granted the government’s request to stay the injunction, reinstating the BOI reporting requirement. FinCEN responded by extending the filing deadline by two weeks.
December 26, 2024: A different Fifth Circuit panel reversed the December 23 decision, reinstating the nationwide injunction and halting the BOI reporting requirement once again.
February 18, 2025:FinCEN notified businesses that the U.S. District Court for the Eastern District of Texas reinstated the BOI reporting requirements.
March 2, 2025: The Treasury Department announced today that it will not enforce any penalties or fines related to the beneficial ownership information reporting
Resource Links to Learn More:
- Find guidance materials and additional information: https://www.fincen.gov/boi
- Subscribe to immediate email updates about Beneficial Ownership Information: https://service.govdelivery.com/accounts/USFINCEN/subscriber/new
