Log Out

VSCPA advocates for delay in BOI reporting requirements

September 20, 2023

On Aug. 30, 2023, the VSCPA requested Virginia's federal legislators cosponsor the "Protecting Small Business Information Act of 2023" (S. 2623 / H.R. 4035) to delay the Beneficial Ownership Information (BOI) reporting requirements for small businesses.

The BOI reporting requirement is an anti-money laundering initiative enacted through the Corporate Transparency Act (CTA) in 2021, which mandates that BOI information is reported to the Financial Crimes Enforcement Network (FinCEN).

In conjunction with the AICPA, we're continuing efforts to delay the implementation of BOI and allow for additional time for small businesses and their CPA business advisors to understand the potential impact of these reporting requirements, including steep penalties for non-compliance.

The VSCPA is among a large number of accounting professionals advocating for this delay, including the AICPA and a coalition of other concerned organizations.

An example of our correspondence is below.

Dear representative,

The Virginia Society of CPAs (VSCPA) has serious concerns with the Beneficial Ownership Information (BOI) reporting requirements small businesses will be required to submit to the Financial Crimes Enforcement Network (FinCEN) beginning in 2024. This reporting requirement is expected to heavily impact small firm CPA practitioners in our state and their small business clients. Across the country, small businesses are not universally aware of the rule.  We believe, come January, many will be unprepared to meet their reporting obligation and face significant consequences including civil and criminal penalties should they fail to report.


Legislation introduced in the U.S. Senate would provide CPAs — the trusted financial professionals who assist small businesses with certain reporting requirements — the necessary time to prepare for BOI reporting. S. 2623, the Protecting Small Business Information Act of 2023, would delay the BOI reporting requirements until all three rules under the Corporate Transparency Act have all been finalized and that all such rules would take effect on the same date. The VSCPA strongly supports this legislation, and we ask that [the representative] cosponsor this bill.


Thank you so much for your consideration and please reach out to me with any questions.



Emily Walker, CAE
Vice President, Advocacy

Virginia Society of CPAs