Beneficial Ownership Information (BOI) reporting is back, with a deadline of March 21, 2025, for most reporting companies to file an initial, updated, or corrected BOI report.
In the next 30 days, FinCEN will evaluate how they prioritize entities with greater potential risk to national security and will assess its options for further modifying deadlines. Over the next year, FinCEN also plans to adjust the BOI reporting requirements to reduce the burden on lower-risk entities, including many U.S. small businesses.
Legislative efforts to delay the reporting deadline are ongoing. On February 10, 2025, the House unanimously passed the Protect Small Businesses From Excessive Paperwork Act of 2025 (H.R. 736), which would delay the mandatory BOI reporting requirement due date to January 1, 2026, for entities formed before January 1, 2024. The bill has now been sent to the Senate.
Lanigan Ryan strongly encourages any entity deemed a reporting company under the Corporate Transparency Act to file their BOI reporting by the extended deadline if they have not already done so.
If you have any questions about the legal implications of these recent court or legislative proceedings, or need a legal determination on whether an exemption applies to your entity or whether legal relationships constitute beneficial ownership, we strongly encourage you to consult legal counsel with expertise in this area to assist your organization.
