In a major development, FinCEN has effectively hit the brakes on Beneficial Ownership Information (BOI) reporting, indefinitely delaying enforcement. In a February 27, 2025, press release, FinCEN confirmed that it will not issue fines, penalties, or take any enforcement action against companies that do not file their BOI reports—at least for now.
What’s the New Timeline?
FinCEN has signaled that enforcement will resume only after a forthcoming interim final rule is issued and its new deadlines have passed. The rule is expected to be released by March 21, 2025, but that’s just the start of what could be an extended process. A public comment period could stretch anywhere from 30 to 180 days, making it uncertain whether a final rule will be in place by the end of the year. And once the rule is finalized, there will likely be a new round of legal challenges to further delay implementation.
What Does This Mean for Business Owners?
If you haven’t filed your BOI report yet, you do not need to take any action until further notice. FinCEN’s announcement removes any immediate compliance pressure, providing businesses with time to wait for clearer guidance on deadlines and requirements.
Legal Challenges Continue
FinCEN’s decision also gives the Fifth and Eleventh Circuit Courts of Appeal room to issue rulings on the constitutionality of the Corporate Transparency Act (CTA). Both courts have cases (NSBA v. Yellin before the Eleventh Circuit) and Texas Top Cop Shop before the Fifth Circuit) where lower courts found the CTA unconstitutional. Depending on the outcomes, these cases could ultimately be appealed to the U.S. Supreme Court, or, if the government loses, it may choose to let the rulings stand rather than push forward with enforcement.
Legislative Action on the Horizon?
Meanwhile, the Senate may take up a recently passed bipartisan bill that would extend the BOI reporting deadline until January 1, 2026. With enforcement already on pause, this legislative move could further push back mandatory compliance requirements.
Bottom Line
For now, businesses are in the clear, meaning BOI report filings are not required until FinCEN provides further guidance. However, staying informed is key, as legal and regulatory shifts could change the landscape yet again. Keep an eye out for updates on new deadlines and compliance requirements.
If you have any questions about your reporting obligations or potential future compliance, feel free to click here to schedule a 15-minute call to learn more and to start our planning process today. In the meantime, we will continue monitoring these developments and keep you posted on what comes next.