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Beneficial ownership information requirements are back with a new deadline and – so far – nothing in the legal pipeline stands in their way.
After multiple court decisions changed the course of the BOI rules under the Corporate Transparency Act, the latest decision this week lifted a nationwide injunction and clears the way for the law to go into effect. On Wednesday, February 19, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced a March 21, 2025, deadline for companies to meet BOI requirements. FinCEN, the agency tasked with oversight of the law, announced the new deadline in Notice FIN-2025-CTA1 this week.
For the first time in several weeks, there are no legal challenges, active injunctions, or pending appeals that would appear to alter the course of the BOI rule and its new deadline. The U.S. House of Representatives recently approved a bipartisan bill to push the BOI deadline to January 1, 2026, but because the Senate hasn’t yet taken a vote, there’s no indication that it will become law in time to affect the March 21 deadline.
The latest twist in the BOI’s journey came on Monday when a federal district court lifted the final injunction that had put the entire Corporate Transparency Act on hold. The plaintiffs in that case are not expected to appeal.
With the rule again in effect, most companies that were created by filing paperwork with a state agency are required to provide certain information about each of the company’s beneficial owners, including a qualifying ID or driver’s license, legal name, birthdate, and residential address. Failing to do so can lead to a violation of up to $591 each day in addition to criminal penalties.
BOI filings can be submitted at no charge on the FinCEN website, which is updated with the most recent deadlines and changes. The site includes extensive resources to determine whether a business is required to provide the information.
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