Contributed by Kevin M. Granahan and Christopher J. Pippett
The Corporate Transparency Act’s (CTA) reporting requirements are officially back in force, requiring non-exempt entities to disclose beneficial ownership information (BOI).
This week, a Texas federal court lifted the last remaining nationwide injunction that had blocked enforcement of these rules. As a result, most reporting companies must file their BOI reports by March 21, 2025.
What Changed?
The U.S. Financial Crimes Enforcement Network (FinCEN) had repeatedly extended some of the law’s filing deadlines due to a series of court challenges and injunctions that barred enforcement.
After a Department of Justice appeal, the last of those courts agreed to stay its injunction, effectively reinstating the law’s reporting requirements.
With this decision, FinCEN is resuming enforcement but has extended the reporting deadline by 30 days to give companies more time to comply.
Key Takeaways
- March 21, 2025 deadline: Most companies must file their BOI reports by this date.
- Later deadlines in some cases: If your company qualifies for disaster relief extensions or another exemption, follow the extended deadline.
- Potential for further changes: FinCEN is considering additional modifications to ease burdens on small businesses and will provide further updates as necessary.
Failure to comply with BOI reporting requirements can result in significant penalties, including fines of up to $10,000 and potential criminal liability. For more details and to file your BOI report, visit FinCEN’s E-Filing System.
The members of Fox Rothschild’s CTA Compliance Team continue to monitor court challenges to the CTA and will provide relevant updates as they become available. In the meantime, our attorneys are available to assist with your CTA compliance questions. Contact Kevin Granahan, Christopher Pippett or a Franchise and Distribution attorney at Fox Rothschild with whom you maintain a relationship.