Apr 07, 2025

BOI Reporting Obligations Reinstated--And Then Removed Again

Because of various court rulings, the beneficial ownership information reporting requirement for small businesses has been bouncing back and forth. Click through for the latest on Corporate Transparency Act requirements.

The Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) is the agency that enforces the Corporate Transparency Act (CTA). Earlier in 2025, FinCEN sent out a notice indicating a new deadline of March 21 for small businesses to comply with its beneficial ownership information (BOI) reporting requirement.

But on March 21, it announced that it was relieving domestic companies from all reporting requirements going forward, although foreign companies still have to comply. Go the FinCEN site for further details, https://fincen.gov/. 

How did we get here?

Arguments against the CTA suggest that the reporting requirements are overly broad and burdensome for some small businesses. The CTA legislation was originally designed to combat illicit financial activities.

Still, before the March 21 announcement, a Treasury official noted that “in keeping with the Treasury’s commitment to reducing regulatory burden on businesses,” the agency would “assess its options to modify further deadlines or reporting requirements for lower-risk entities, including many U.S. small businesses, while prioritizing reporting for those entities that pose the most significant security risks.”

How has FinCEN responded?

Again, before the March 21 announcement, FinCEN gave a nod to its intention to do just that, writing on its website, “FinCEN will assess its options for further modifying deadlines.” At the same time, there are other CTA case appeals on other court dockets, but the courts have declined to issue a preliminary injunction on behalf of plaintiffs challenging the constitutionality of the CTA.

What's happening in Congress

The House unanimously passed H.R. 736, the Protect Small Business from Excessive Paperwork Act, which would postpone the BOI reporting deadline for one year for most companies—those reporting companies formed or registered before January 1, 2024. The bill pushes the new reporting deadline to January 1, 2026, but it’s not certain when or if the Senate may move the bill—currently in the Banking, Housing and Urban Affairs committee—to the floor for a vote.

Another bill—known as the Repealing Big Brother Overreach Act—would toss the reporting requirements for good and attempt to eliminate the Corporate Transparency Act. However, this bill doesn’t have bipartisan support and it is sitting in committee.

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