Beneficial Ownership Information (BOI) reporting was set to become a critical new requirement for businesses starting on January 1, 2024. The initial filing deadline for businesses created before 2024 was December 31, 2024. However, a recent court ruling has placed these requirements on hold.
Breaking News: BOI Reporting Halted by Nationwide Injunction
On December 3, 2024, a federal district court in Texas issued a nationwide preliminary injunction against enforcing the BOI reporting requirements mandated by the Corporate Transparency Act (CTA). In the case Texas Top Cop Shop v. Garland (U.S. Dist. Ct., Eastern Dist. of Texas, Case No. 4:24-CV-478), the court ruled that Congress exceeded its authority by enacting the CTA, infringing on states’ rights to regulate businesses.
As a result, FinCEN is prohibited from enforcing the January 1, 2025, reporting deadline for all reporting companies across the country. This means that, for now, businesses are not required to file BOI reports. However, this legal battle is far from over, and the final outcome could significantly impact your business's compliance responsibilities—here’s what you need to know to stay ahead.
What Does This Mean for Your Business?
Although the BOI reporting requirement is currently paused, this injunction may be temporary. The decision is expected to be appealed, and future developments could reinstate the filing requirement. Therefore, businesses should remain informed and prepared to file if the injunction is lifted.
In the meantime, here’s what you need to know about BOI reporting, should the requirements be reinstated:
What Is the BOI Report?
The BOI report is a document filed with the U.S. Treasury and monitored by FinCEN (the Financial Crimes Enforcement Network). It provides detailed information about the owners and key individuals associated with a business.
This reporting requirement was established under the Corporate Transparency Act (CTA) of 2021, which aims to:
Prevent individuals from using business ownership or control to facilitate illegal activities.
Protect U.S. national security, financial systems, and economic integrity from both foreign and domestic threats.
Why Do I Have to File?
Had the injunction not been issued, most small businesses that filed incorporation or registration documents with a Secretary of State would have been required to file a BOI report. According to Venable LLP's analysis of the Corporate Transparency Act, the U.S. government estimated that around 30 million small businesses would need to comply, although some exceptions exist for regulated industries like insurance, banking, and accounting.
Who Can Access This Filing?
If the requirement is reinstated, FinCEN and various government and law enforcement agencies—both domestic and international—will have access to this information.

Given the sensitivity of the data, accuracy will remain critical. Aligning the report with your articles of incorporation and ownership structure will help avoid costly errors if filing becomes necessary in the future.
Should I File It Myself?
While the BOI report may seem straightforward, filing errors can lead to significant penalties. According to FinCEN, mistakes or failures to file can result in fines of up to $600 per day and potential prison sentences of up to two years.
Even though the filing requirement is temporarily suspended, we recommend consulting a CPA or attorney to stay prepared for any future changes. If you choose to file independently when required, be sure to thoroughly review the laws and requirements.
Stay Informed
At Donnelly-Boland, we are closely monitoring this situation and will continue to provide updates as new information becomes available. While the current injunction offers a temporary reprieve, staying proactive and informed is essential to avoid potential compliance issues if the ruling is overturned.
For any questions or concerns about BOI reporting and its implications for your business, feel free to reach out to our team.
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