Take Action: BOI Filings due March 21, urge U.S. Senate to delay until 2026

The last remaining nationwide injunction blocking the Corporate Transparency Act (CTA) and its beneficial ownership information (BOI) reporting requirement from being enforced was stayed (lifted) by a federal district court in the Samantha Smith case on Feb. 17. The U.S. Supreme Court had already lifted the nationwide injunction in the Texas Top Cop Shop case on Jan. 23. 

As a result, FinCEN has announced that the new reporting deadline is March 21, 2025. For more information, click here. FinCEN also has been providing updated alerts: https://fincen.gov/boi. 

FinCEN’s Feb. 19 notice states that it “will provide an update before then (March 21) of any further modification of this deadline, recognizing that reporting companies may need additional time to comply with their BOI reporting obligations once this update is provided.” 

However, details of any modifications that FinCEN is considering are not currently available. AICPA and the state societies continue to urge FinCEN to grant a longer extension period than a 30-day filing extension. 

In a positive development, Congress passed H.R. 736 by a vote of 408-0 on Feb. 10. This bill, called the Protect Small Businesses from Excessive Paperwork Act of 2025, would delay BOI reporting until January 1, 2026. The bill has been referred to the U.S. Senate Committee on Banking, Housing, and Urban Affairs, and Chair Tim Scott (R-SC) has introduced his own version of the legislation, S.505. For more information, click here. Neither of these bills provide BOI filing relief for entities formed on or after Jan. 1, 2024. 

There is likely not enough support in the Senate for the bill to move through the unanimous consent expedited process, but there is hope that it will be attached to a must-pass vehicle soon.  The Ohio Society has activated our “Take Action” page so members can reach out to Ohio’s U.S. Senators Jon Husted and Bernie Moreno and urge passage of this legislation.   

Please take action: https://ohiocpa.com/advocacy/Take_Action#/