The deadline for reporting companies to file beneficial ownership information (BOI) reports under the Corporate Transparency Act (CTA) may be extended by one year, moving from Jan. 1, 2025, to Jan. 1, 2026. This potential extension is part of a continuing resolution currently being considered in Congress.
The 1,500-page funding bill, designed to prevent a government shutdown by extending government funding through March 14, 2025, includes language amending the reporting deadline. The proposed change specifies that reporting companies formed or registered before Jan. 1, 2024, would now have until Jan. 1, 2026, to file their BOI reports.
Background on BOI Reporting
The BOI reporting requirements, introduced as part of the CTA in 2021, aim to combat money laundering by increasing transparency about the beneficial owners of certain entities. Under these rules, reporting companies must disclose information about their beneficial owners and, for entities formed after Jan. 1, 2024, the individuals who filed their incorporation documents (referred to as "applicants").
Legal and Legislative Developments
BOI reporting has been subject to legal challenges, with a recent Texas court decision issuing a preliminary injunction that blocks the enforcement of the CTA and its BOI reporting rules nationwide. The Department of Justice (DOJ) has appealed this ruling and requested a decision by Dec. 27 to clarify the requirements for reporting companies ahead of the original Jan. 1, 2025, deadline.At the same time, Congress is considering legislative action to extend the deadline. The resolution must pass both the House and Senate to take effect.
Next Steps for Businesses
As developments around the BOI reporting requirements continue to unfold, businesses should stay informed about potential changes to the deadline and compliance obligations. While the proposed extension may provide additional time, it is important to remain prepared for reporting requirements once they are finalized.
For personalized guidance on how these changes might affect your business, we encourage you to reach out to your attorney. Legal professionals can provide the most up-to-date advice and ensure your business is ready to comply when the final rules are confirmed.
