After this story was published, the 5th Circuit Court of Appeals issued a ruling that puts this reporting requirement on hold once again. Please click here for updated information. 

A last-minute court of appeals ruling could put tens of thousands of farmers in legal crosshairs for failing to register their businesses with the federal government. Farmers who operate corporations and limited liability companies are once again required to file Beneficial Ownership Information with the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) or face stiff fines or jail time.

A federal district court ruled earlier in December to halt the requirement, but the United States Court of Appeals for the Fifth Circuit lifted the injunction on Dec. 23, meaning the January 2025 deadline is back in effect.

Analysis from American Farm Bureau Federation (AFBF) economists shows more than 230,000 farms are required to file under the Corporate Transparency Act, but as of October, less than 11% of all eligible businesses nationwide had done so.

“Farm Bureau is very disappointed in the court of appeals decision to reinstate the Jan. 1 filing deadline,” AFBF President Zippy Duvall said. “It’s clear than many farmers aren’t aware of the filing requirement because of lack of guidance and the government’s poor public outreach.”

Reporting deadlines and details
Reporting companies that were created or registered prior to Jan. 1, 2024 have until Jan. 13, 2025 to file their initial beneficial ownership information reports with FinCEN. (These companies would otherwise have been required to report by Jan. 1, 2025.)

Reporting companies created or registered in the United States on or after Sept. 4, 2024 that had a filing deadline between Dec. 3, 2024 and Dec. 23, 2024 have until Jan. 13, 2025 to file their initial beneficial ownership information reports with FinCEN.

Reporting companies created or registered in the United States on or after Dec. 3, 2024 and on or before Dec. 23, 2024 have an additional 21 days from their original filing deadline to file their initial beneficial ownership information reports with FinCEN.

Reporting companies that qualify for disaster relief may have extended deadlines that fall beyond Jan. 13, 2025. These companies should abide by whichever deadline falls later.

Reporting companies that are created or registered in the United States on or after Jan. 1, 2025 have 30 days to file their initial beneficial ownership information reports with FinCEN after receiving actual or public notice that their creation or registration is effective.

Businesses that fail to file under the Corporate Transparency Act, or do not update records when needed, could face criminal fines up to $10,000 and additional civil penalties of up to $591 per day. Failure to file could also lead to felony charges and up to two years in prison.

Farmers are encouraged to contact an accountant or attorney if they are unsure whether they are required to file their business’s BOI with FinCEN.

Additional information
View the FinCEN FAQs about the Beneficial Ownership Information Reporting rule.

View the FinCEN Small Entity Compliance Guide.