BOI Reporting Deadline Extended—But Don’t Wait to File
February 2025 | Category: News
By Rebecca Urland Monzi
If you can’t keep up with the BOI Reporting rollercoaster of the past few months, you are not alone. The stay on FinCEN BOI filings related to litigation in Texas was just lifted this week. As a result, FinCEN has extended the reporting period to March 21, 2025. Notwithstanding the extension, FinCEN also stated that prior to the new deadline it will be “assessing its options” to potentially further modify the deadline, as it claims to now be prioritizing reporting for those entities that pose the most significant national security risks (notably, FinCEN has not stated how it will determine those entities). FinCEN has also stated that it intends to initiate a process this year to revise (but not eliminate) the BOI reporting rule to reduce the burden for lower-risk entities. It is unclear when, if at all, FinCEN will provide an update potentially revising the reporting obligations or further extending the deadline.
There has also been action in the House, with a bill (H.R. 736 – Protect Small Businesses from Excessive Paperwork Act of 2025) recently passed (unanimously) to delay the BOI reporting deadline. This bill would postpone the reporting deadline to January 1, 2026. The legislation was introduced into the Senate last week and has been referred to committee. There is not a date yet for the Senate to vote (it will likely take a few weeks to get through committee), but even if it is voted on within the 30-day extension period set by FinCEN, the President then has 10 days to sign or veto.
Although it is possible that FinCEN extends the March 21st deadline, or it is extended by Congressional action, since we don’t know when further guidance will be given, companies should strongly consider filing now, if they haven’t already. It is apparent that the filing requirements will not be going away anytime soon.
Rebecca Urland Monzi is a commercial real estate and corporate attorney. For more information, contact rmonzi@fmlaw.com.
The content on this blog is for informational purposes only and does not constitute legal advice. The information provided should not be relied upon as a substitute for professional legal counsel.