On February 18, Eastern District of Texas Judge Jeremy Kernodle reinstated the enforcement of the Corporate Transparency Act (CTA), reversing the injunction he issued a month prior. The future of the CTA was uncertain after a December 2024 ruling challenged the constitutionality of the CTA, issuing a preliminary injunction and halting enforcement nationwide.
The Financial Crimes Enforcement Network (FinCEN) issued a notice on February 18, extending the filing deadline to March 21, 2025, to give companies time to comply with Beneficial Ownership Information (BOI) reporting obligations. In the notice, FinCEN stated that additional deadlines may be available to businesses, and entities already given an additional deadline must adhere to that date.
When Should I File?
According to FinCen, most companies must adhere to the upcoming deadline of March 21, 2025. If you are unsure if your business qualifies for an extension or is exempt, the latest deadlines from the February 18 FinCEN notice can be found below:
New Deadline: Most companies must file their initial, updated, or corrected BOI report by March 21, 2025.
Possible Extension: FinCEN may update the deadline and allow more time if needed.
Later Deadlines Apply: If your company already has a later deadline (e.g., due to disaster relief extensions), follow that deadline instead.
Exemption: Businesses and individuals involved in the National Small Business United v. Yellen lawsuit (as of March 1, 2024) do not need to report their BOI at this time.
What’s Next?
If your business is affected by the Reporting Rule, it’s important to stay updated on the situation and consult your CTA advisor to determine your compliance timeline and prepare BOI reports. Our Corporate and Securities team is here to help with any questions about BOI filing deadlines and compliance. Click here to contact us today.
