The saga of the beneficial ownership information (BOI) reporting under the Corporate Transparency ACT (CTA) rages on.

On February 18, 2025, the U.S. District Court for the Eastern District of Texas lifted the nationwide injunction on CTA enforcement, thereby reinstating the BOI reporting requirements.

This should be the last of the many obstacles that has had the implementation of this requirement start and stop a number of times.

In response to this most recent decision, the Financial Crimes Enforcement Network (FinCEN) has extended the deadline for most companies to file their initial BOI reports to March 21, 2025. This extension applies to existing entities and provides them with additional time to comply with the reporting requirements.

Key Deadlines

The CTA imposes different deadlines for various types of companies:

• Companies formed before January 1, 2024: Must file their initial BOI reports by March 21, 2025.
• Companies formed between January 1, 2024, and February 18, 2025: Must file their BOI reports by March 21, 2025.
• Companies formed after February 18, 2025: Must file their BOI reports within 30 days of formation or registration.
• Companies that are under disaster recovery relief have until the extended due date under those provisions, presumably May 1, 2025.

FinCEN has indicated that it will assess options to further modify deadlines and may prioritize reporting for entities posing significant national security risks. Additionally, the U.S. House of Representatives passed H.R. 736, which, if enacted, would extend the BOI reporting deadline for companies formed or registered before January 1, 2024, to January 1, 2026.

Brief History of CTA Implementation

The CTA’s journey to implementation has been marked by several key milestones:

• January 1, 2024: CTA reporting requirements initially took effect.
• December 3, 2024: A U.S. District Court issued a preliminary injunction, halting CTA enforcement nationwide.
• December 23, 2024: The Fifth Circuit Court of Appeals temporarily revived the January 1, 2025 deadline.
• December 26, 2024: The Fifth Circuit vacated its previous decision, once again halting enforcement.
• February 18, 2025: The U.S. District Court lifted the injunction, allowing CTA enforcement to resume.
• February 19, 2025: FinCEN announced the new March 21, 2025 deadline for most reporting companies.

Conclusion

The CTA’s BOI reporting requirements are now back in effect, with the new compliance deadline set for March 21, 2025, for most entities. Businesses must ensure they understand their obligations, gather the required information, and file reports promptly to avoid penalties. FinCEN continues to provide resources, including updated compliance guides, FAQs, and toolkits, to assist businesses in meeting their obligations.

Please contact your attorney regarding these filing deadlines or let us know if you have any questions about how to proceed.