US District Court Resumes CTA BOI Reporting Requirements as FinCEN Extends Deadline

A nationwide preliminary injunction put in place on January 7, 2025 by a district court in Texas has been stayed pending appeal, reinstating the reporting requirements of the Corporate Transparency Act (CTA). However, the Financial Crimes Enforcement Network (FinCEN) has issued a 30-day delay for the vast majority of reporting companies, making the new deadline March 21, 2025.

On February 18, 2025, the US District Court for the Eastern District of Texas stayed its own injunction on the CTA’s beneficial ownership information (BOI) reporting requirements, clearing the way for enforcement of the CTA to continue immediately. In response, FinCEN issued new guidance extending the deadline to submit initial, updated, or corrected BOI reports for the majority of companies by an additional 30 days, now due by March 21, 2025.

Per FinCEN’s guidance, companies that had previously been granted extensions later than the March 21, 2025 deadline, such as those affected by disaster relief, should continue to follow their original filing deadlines. In addition to extending the general deadline, FinCEN stated that during the 30-day extension period it will assess its options to further modify deadlines while prioritizing reporting for those entities that pose the most significant national security risks. FinCEN also said that it intends to initiate a process this year to revise the BOI reporting rule, if necessary, with a focus on reducing the burden on lower-risk entities, including many small businesses in the United States.

A legislative effort to extend the reporting deadline until January 1, 2026 is ongoing, with an extension bill having passed the US House of Representatives in early February. Further, we are monitoring any executive action applicable to implementation of the CTA.

In any event, we will continue to monitor developments and provide updates as necessary to ensure compliance with the CTA’s reporting requirements.