BOI Reporting Reinstated: What Small Business Owners Need to Know

Update: FinCEN Reporting Requirements Reinstated

Following a federal Court of Appeals decision on December 23, 2024, FinCEN's beneficial ownership reporting requirements are back in effect, with adjusted deadlines to accommodate the transition period.

Companies created or registered before January 1, 2024 now have until January 13, 2025 to file their initial reports. Companies established between September and December 2024 have varying extended deadlines, with most falling on or before January 13, 2025. Going forward, new companies created after January 1, 2025, will need to file within 30 days of their registration. Additional details available on FinCEN's website here: https://fincen.gov/boi.

Here is the original text of this blog post:

If you’ve been preparing for the Beneficial Ownership Information (BOI) reporting requirements under the Corporate Transparency Act, there’s a new development you should know about. On December 3, 2024, a Texas federal court has issued a nationwide injunction that halts the enforcement of these rules, originally set to begin January 1, 2024.

This injunction provides a temporary reprieve for small business owners who were gearing up to comply with these new obligations. However, it’s important to stay vigilant. This pause in enforcement doesn’t necessarily mean the BOI reporting requirements are gone for good—the situation is still evolving.

What is BOI Reporting?

BOI reporting, as we explained in our previous post, "BOI Reporting: What Small Business Owners Need to Know", requires businesses to disclose key information about their beneficial owners to the Financial Crimes Enforcement Network (FinCEN). These rules aim to increase corporate transparency but also pose new compliance challenges for small businesses.

For more context on the legal decision, see this article from the National Law Review.

Key Updates on the Injunction

For now, here are some key takeaways about the injunction:

  • Pause Compliance Efforts: While the injunction is in place, enforcement of BOI reporting is on hold. There’s no immediate need to submit filings.
  • Stay Updated: Keep an eye on legal developments and updates from FinCEN.
  • Be Prepared: Use this time to gather information and ensure your business is ready to comply if the injunction is lifted.

Why This Matters to Small Business Owners

The BOI reporting requirements—and this injunction—could significantly impact how you manage your business’s compliance processes. While this pause provides some breathing room, it’s essential to remain proactive.

Next Steps for Small Businesses

  1. Review the Basics: Familiarize yourself with BOI reporting requirements using our previous blog post.
  2. Monitor Developments: Follow updates from trusted sources like FinCEN and legal experts.
  3. Prepare for the Future: Use this time to organize beneficial ownership information and streamline internal processes for potential compliance needs.

At Eucalyptus, we’re committed to helping small business owners navigate complex regulatory changes like this. If you have questions or want to discuss how this impacts your business, reach out to us today.