Corporate Transparency Act BOI Reporting Resumes: DUE MARCH 21, 2025

On February 18, 2025, the U.S. Federal District Court for the Eastern District of Texas lifted the last remaining nationwide injunction against the CTA. As a result, the Corporate Transparency Act is back in effect and the new BOI reporting deadline is now March 21, 2025. BOI reports should be filed through FinCEN’s website at https://fincen.gov/boi. 

On February 19, 2025 FinCEN provided additional guidance, indicating that during the next 30 days it will assess its options to further modify deadlines, while prioritizing reporting for entities that pose the most significant national security risks. FinCEN 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.

Meanwhile, Congress has taken action to potentially delay the BOI reporting. The House passed (H.R. 736 - Protect Small Businesses from Excessive Paperwork Act of 2025) last week. If passed by the Senate, the bill would extend the BOI reporting deadline to January 1, 2026. As of today, the Senate has not taken meaningful action on this bill.

We recommend that you review your reporting obligations under the CTA and ensure compliance by the March 21, 2025 deadline and, if necessary, consult with legal counsel to determine your compliance obligations. With millions of BOI reports still expected to be filed, FinCEN is recommending companies file their reports promptly.

If you have any questions or need assistance, please do not hesitate to contact us.