Corporate Transparency Act

As of March 21, 2025, the reporting requirement has been removed for U.S. companies and U.S. persons, Read below for more information

Beware of scams

There are many companies out there ready to charge you for this free filing. Although you may choose to have your tax preparer or attorney file for you at a price you agree upon, it's important to know you can file your own for free on the government website. 

You may have received emails reminding you of this new reporting law. Many have links that take you to a non-government website and charge a fee without telling you that you can file for free. Because you need to have proof this filing occurred and access to the transcript, only pay a trusted source if you want them to do it for you and agree on the price. For most small businesses this filing takes 6-8 minutes to do on your own. The government site to file is https://www.fincen.gov/boi

Current status

The filing requirement has changed to remove any requirement for US companies. The rule now only applies to foreign companies doing business in the US. 

On March 21, 2025 FinCEN announced the following: 

"Consistent with the U.S. Department of the Treasury’s March 2, 2025 announcement, the Financial Crimes Enforcement Network (FinCEN) is issuing an interim final rule that removes the requirement for U.S. companies and U.S. persons to report beneficial ownership information (BOI) to FinCEN under the Corporate Transparency Act."

Timeline: 

• 2024: Filing opened for this new Beneficial Ownership Information reporting requirement
• 12/4/24: An injunction was issued by a federal court stopping the government from requiring this or penalizing business owners who do not file.
• 12/23/24: An appeal court reversed the injunction again making the filing a requirement for certain business owners. The government then changed the deadline for businesses that existed on 1/1/24 from a filing deadline of 1/1/25 to 1/13/25, giving a few more days to file.
• 12/26/24: An appeal court reversed the reversal of the injunction, making the original 12/4/24 injunction effective again. This made the filing voluntary for a second time.
• 2/18/25: A US District Court reinstated the filing requirement. FinCEN then extended the deadline for most businesses to March 21, 2025. 
• 2/27/25: FinCEN announced they will not issue any fines or penalties or take any other enforcement action against business owners that have not filed. 
• 3/21/25 FinCEN announced they had removed the reporting requirement for U.S. companies and U.S persons. The rule now only applies to certain foreign companies operating in the U.S. This is the current status. 

General information

The Corporate Transparency Act created this new filing requirement for certain business owners, call the Beneficial Ownership Information Report (BOI or BOIR). 

The filing can be done for free on the FinCEN website below. For most small businesses this filing takes 6-8 minutes. It is a one time filing, which you would then update if there are any changes to the business, ownership or owner information. 

These FinCEN websites provide information on the filing: 

• FAQ: https://www.fincen.gov/boi-faqs
• Small business resources: https://www.fincen.gov/boi/small-business-resources
• Small entity compliance guide: https://www.fincen.gov/boi/small-entity-compliance-guide

FAQ 1: Do I need to file? 

If you have not yet filed, the filing requirement for U.S. companies and U.S persons has been removed. If you operate a foreign business in the U.S. consult the current FinCEN requirements to determine if filing is required. 

FAQ 2: What if I already filed? 

If you already filed there is nothing to do. There is no information on what happens to the data for companies and individuals that have already filed, but there is no expectation the info needs to be updated in the future unless the requirement changes. 

FAQ 3: What if I paid someone to file for me? 

If you expect you were scammed, first make sure you have the transcript and proof of whether it was actually filed. You can dispute a charge with your credit card company, but there is nothing really stopping someone from paying a service to file the report, so it may not be a successful dispute.

There are always lots of scammers targeting people to pay fees for things that are free, like getting employment posters or getting an Employer Identification Number (EIN). Receiving emails or letters about government requirements can be intimidating and it is easy to fall for these scams. A good step is to make sure you are only getting your info from a .gov website.