BOI Reporting Is on Hold: What You Need to Know

Introduction: A Big Win for Small Business Owners

If you’re a small business owner wondering what’s happening with Beneficial Ownership Information (BOI) reporting under the Corporate Transparency Act (CTA), there’s some good news: BOI reporting is on hold—for now.

A recent Texas court ruling has paused BOI reporting requirements nationwide, giving small businesses a break from what many saw as confusing and burdensome paperwork. But what does this ruling mean for you? Should you still prepare? And will the law come back?

Let’s break down everything you need to know about:

• Why BOI reporting is paused.
• What the court ruling said.
• What small business owners should do next.

Let’s dig in!

What Is BOI Reporting, and Why Was It Introduced?

BOI reporting is part of the Corporate Transparency Act (CTA), a federal law passed in 2021. It requires businesses to report details about their “beneficial owners”—the individuals who own or control at least 25% of a company.

The goal? To prevent financial crimes like money laundering, tax evasion, and fraud by making it harder to hide ownership behind shell companies.

Businesses were expected to file this information with the Financial Crimes Enforcement Network (FinCEN) starting January 1, 2025.

Sounds straightforward, right? Well, not exactly. Many small business owners argued the law was confusing, overly intrusive, and added an unnecessary compliance burden.

What Did the Texas Court Rule?

On December 3, 2024, a federal court in Texas issued a nationwide preliminary injunction against the BOI reporting requirements in the case Texas Top Cop Shop, Inc. v. Garland.

Here’s what the court said:

• The Corporate Transparency Act likely exceeds Congress’s authority.
• The law is “quasi-Orwellian”—a term that references George Orwell’s 1984, where government overreach leads to privacy concerns.
• Forcing small businesses to disclose private ownership data could infringe on states’ rights and individuals’ privacy.

The Result: BOI reporting is on hold nationwide, and small business owners are no longer required to file—at least for now.

Is BOI Reporting Voluntary or Required?

Right now:

• BOI reporting is paused.
• There are no penalties for not filing.
• If you still want to file, FinCEN is accepting voluntary submissions—but there’s no obligation.

However, the Department of Justice (DOJ) has already appealed the Texas court’s decision, which means this pause might not be permanent.

What Does This Mean for Small Business Owners?

For small business owners, this ruling provides some much-needed relief. The BOI reporting deadline had created a lot of confusion and extra work, especially for businesses with limited time and resources.

Here’s what the pause means for you:

1. No Immediate Action Required: You don’t need to file a BOI report right now.
2. No Penalties: There’s no punishment for skipping BOI reporting while the injunction is in effect.
3. Temporary Relief: The law may come back depending on how the appeal unfolds.

What Should Small Business Owners Do Next?

Even though BOI reporting is paused, it’s still smart to prepare just in case. Here’s what we recommend:

1. Stay Informed

The situation could change quickly. Keep an eye on updates from:

• FinCEN: fincen.gov/boi
• Industry updates from trusted sources (like us!).

We’ll keep you posted if anything changes.

2. Gather Your Information

While filing isn’t required right now, it doesn’t hurt to get organized. Here’s what you’d need for a BOI report:

• Beneficial owners’ names, addresses, and birthdates.
• A copy of their government-issued ID.

If the law comes back, you’ll be ahead of the game.

3. Consult Your Advisors

If you’re unsure about how BOI reporting impacts your business, talk to your accountant, CPA or lawyer, to help you understand what’s required and how to prepare.

Will BOI Reporting Come Back?

It’s possible. The DOJ appeal means higher courts will review the Texas ruling. If the appeal succeeds, BOI reporting requirements could be reinstated.

We don’t have a crystal ball, but we’ll be watching closely so you don’t have to.

Key Takeaways: BOI Reporting Made Simple

1. BOI reporting is on hold due to a Texas court ruling.
2. Small business owners are not required to file, and there are no penalties for skipping it right now.
3. The situation is evolving—stay informed and get organized, just in case.

Stay Ahead with Perlinger Consulting

At Perlinger Consulting, we know small business compliance can feel overwhelming—especially when the rules keep changing. That’s why we’re here to keep you informed, prepared, and focused on what matters most: running your business.

If you have questions about BOI reporting or need help navigating compliance updates, reach out anytime. We’re always happy to help!

Perlinger Consulting | Your Partner in Small Business Success
📞 720.290.4389 | 🌐 perlingerconsulting.com

Disclaimer:
The information provided in this blog post is for informational purposes only and does not constitute legal, financial, or professional advice. While we strive to keep content accurate and up to date, laws and regulations may change, and court rulings may impact compliance requirements. We recommend consulting with qualified legal or accounting professionals to determine how this information applies to your specific business situation.

Perlinger Consulting is here to keep you informed and prepared, but this post is not a substitute for personalized advice.