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The On-Again, Off-Again, Now-On-Again BOI Filing Requirement for Fleets
Rob Carpenter
6 min read
Fleets operate under a never-ending, often confusing web of regulations, from DOT compliance to fuel tax reporting and now, for sure, beneficial ownership information (BOI). BOI reporting has become another layer of legal complexity. While the Corporate Transparency Act (CTA), which mandates BOI filing, was designed to combat financial crimes like money laundering, fraud and tax evasion, its implementation has been anything but smooth. Litigation has cast uncertainty over its future, leaving many businesses unsure whether to comply or if the law will be overturned.
This uncertainty is frustrating for trucking companies. Fleets already face significant regulatory burdens that impact daily operations, and now they are being asked to file sensitive ownership information with the Financial Crimes Enforcement Network (FinCEN). Yet, with courts weighing in and FinCEN pushing forward, trucking businesses must figure out what BOI reporting entails, why it applies to them, and what risks come with non-compliance.
What Is BOI Reporting and Why Was It Created?
BOI reporting is a federal requirement under the CTA, which was passed in 2021 as part of a broader effort to increase corporate transparency and reduce financial crimes. The goal is to prevent bad actors from hiding illicit activities behind anonymous business structures. The law requires most U.S. businesses, including small and midsize trucking fleets, to report detailed ownership information to FinCEN.
Unlike public records such as DOT registration or Federal Motor Carrier Safety Administration filings, BOI reports are not publicly available. They are stored in a secure federal database accessible only to law enforcement and authorized agencies. While the law intends to enhance transparency, it creates additional paperwork for legitimate businesses, especially small trucking companies already dealing with compliance-heavy operations.
How Does BOI Reporting Affect Trucking Companies?
Due to the structure of most trucking businesses, BOI reporting heavily impacts them. A trucking company registered as an LLC, S-Corp or partnership likely falls under the “Reporting Company” category and must submit ownership details to FinCEN.
Businesses that must file include:
Owner-operators who formed LLCs for tax and liability reasons.
Small to midsize trucking fleets that operate as corporations or partnerships.
Freight brokerage firms and logistics companies with private ownership structures.
Exemptions exist for large corporations, banks, insurance companies and certain publicly traded businesses, but most privately owned trucking companies must comply unless they meet specific exemption criteria.
One of the key pain points for trucking businesses is that noncompliance carries familiar high civil penalties. If a company fails to file its BOI report on time, FinCEN can impose fines of up to $591 per day, with potential criminal penalties that include fines of up to $10,000 and up to two years in prison for violations. This level of enforcement makes it critical for fleet owners to understand whether they need to file and how to do so correctly.
What Information Do Trucking Companies Need to Report?
For companies required to file, the BOI report must include detailed ownership information for anyone with at least 25% ownership or significant control over the business. This includes providing:
The company’s legal name, address, and Employer Identification Number (EIN).
Name, date of birth and residential address of beneficial owners (anyone with 25%-plus ownership).
Government-issued ID details (such as a passport or driver’s license) for each beneficial owner.
If a company was formed after Jan. 1, 2024, it must also provide information on the person who registered the business, known as the “Company Applicant.” Any changes to this information must be updated within 30 days, or the company could be penalized for failing to maintain accurate records.
Why Is BOI Reporting Causing So Much Confusion?
BOI reporting has been challenged, creating widespread confusion about whether businesses need it. In March 2024, a federal judge ruled that the Corporate Transparency Act was unconstitutional, arguing that Congress overstepped its authority by requiring private businesses to disclose ownership information. This ruling temporarily halted enforcement, leading some businesses to believe they no longer needed to file.
However, FinCEN has continued pushing for deadlines, stating that the law remains in effect for most companies while legal battles continue. As a result, trucking businesses are stuck in regulatory limbo, uncertain whether BOI reporting will stay in place or be overturned entirely.
Adding to the confusion, scammers have begun targeting businesses with fraudulent emails and calls, falsely claiming that fees are required to file a BOI report. In reality, BOI reporting is free to file directly through FinCEN, and companies should be cautious of third-party services attempting to charge unnecessary fees.
How Can Trucking Fleets Ensure Compliance?
Despite the ongoing legal challenges, the safest course of action for trucking companies is to assume compliance is required and prepare accordingly. The best approach is to:
Determine whether your company is subject to BOI reporting requirements. You will likely need to file if you are an LLC, S-Corp or partnership.
Gather ownership details for anyone with at least 25% ownership or significant control over the business.
Submit the BOI report directly through FinCEN before your company’s deadline.
Monitor legal developments, as court rulings may impact enforcement or deadlines.
Be aware that fraudulent services are preying on businesses that are unaware that BOI filings are free.
The filing deadline for businesses formed before Jan. 1, 2024, is March 21, 2025. Businesses formed in 2024 must file within 90 days of registration, and those created after Jan. 1, 2025, must do so within 30 days of their formation.
The Future of BOI Reporting
In January 2025, the U.S. Supreme Court lifted a nationwide injunction on the CTA, allowing FinCEN to enforce its reporting requirements. The law’s future remains uncertain under the Trump administration, which has taken a mixed stance, defending its constitutionality in court while signaling potential reforms to ease the burden on lower-risk businesses. Republican lawmakers have also pushed for repeal, citing concerns over regulatory overreach and privacy. Given Trump’s veto of the CTA in 2021, which Congress overrode, and his pro-business, deregulatory agenda, speculation grows that the CTA may be modified or dismantled. Still, any significant changes would require congressional action and could face opposition from transparency advocates. For now, businesses have to comply while staying alert to shifts in enforcement and legislative developments.
The BOI reporting requirement is another example of how regulations continue to evolve in ways that impact trucking businesses, often without clear guidance or industry-specific considerations. Whether it remains in place, is overturned in court or is modified by Congress, trucking fleets must stay ahead of regulatory changes to avoid penalties.
For now, the best strategy is preparation. Even though the law remains in legal limbo, the risk of fines and enforcement makes it unwise for trucking companies to ignore their compliance obligations. Staying informed, gathering the required information and being ready to file before deadlines will ensure that fleets remain compliant no matter what happens next.
