Published May. 30, 2025 02:30AM EDT
BOI Reports Due March 21
BOI reports are due March 21. This comes after significant on-again, off-again orders from courts in the Fifth Circuit that unfortunately has created substantial confusion. We covered it earlier (here and here). The current state of affairs is that (a) BOI reports are no longer stayed by court order and (b) the US Department of Treasury has made the reports due March 21 (link). The penalty for late filing can be up to $500 a day.
BOI reports, or Beneficial Ownership Information Reports, are reports that identify the owners and managers of businesses. Any business that is created by filing something with the secretary of state of a state is required to file this report with the FinCEN—an agency of the US Department of Treasury. Practically, this means every LLC, S-Corp, and C-Corp needs to file the report. There are exceptions but they are relatively narrow. We outline more about the requirements and exceptions here.
As the history of this report has shown, it remains possible that a court will ultimately conclude that they are not required. It is also possible that another court will independently impose another stay on the requirement. This is what we saw happen in January. A final decision from courts of appeal is not expected until later this year, after the March deadline. If the Supreme Court were to weigh in, that decision would not be published until sometime late this year or early 2026.
For now, we recommend filing the report while the litigation process works its way through the court system. This ensures you avoid any penalties regardless of what courts ultimately decide.
Mid-Atlantic Law & Tax PLLC regularly advises and helps clients navigate the requirements. We have filed over a hundred BOI reports for our clients. Please reach out if you have questions or need assistance filing the report.
