CTA Reporting Requirements Back in Effect—New Deadline of March 21, 2025 for Most Companies

Remaining Injunction Blocking Enforcement of Corporate Transparency Act Reporting Requirements Lifted

On February 18, 2025, a federal court lifted the last remaining nationwide injunction blocking enforcement of the Corporate Transparency Act (CTA).

Thereafter, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) published an alert on its Beneficial Ownership Information (BOI) webpage extending the reporting deadline to March 21, 2025 for most companies.

In the alert, FinCEN also indicated that, during the extension period, it would assess its options to further modify deadlines while prioritizing reporting for those entities that pose the most significant national security risk, and that it also intends to initiate a process this year to revise the BOI reporting rule to reduce the burden for lower-risk entities, including many small businesses. Read the full FinCEN Notice from February 18, 2025.

To recap past developments, enforcement of the CTA and its reporting rules has been subject to certain nationwide injunctions issued by federal courts beginning on December 3, 2024.

Although it is possible that further developments, including action by Congress, may further extend reporting deadlines or alter filing obligations, we recommend that reporting companies take action as soon as possible to comply with the CTA’s new March 21, 2025 reporting deadline. See our client alert, “Reporting Obligations Under the Corporate Transparency Act,” dated July 12, 2024 for general information related to CTA reporting obligations.