Corporate Transparency Act Filing Requirements Reinstated: Beneficial Ownership Information (BOI) Reports Now Due by March 21, 2025

In a notice published on February 18, 2025, FinCEN has issued a new deadline for reporting companies to file beneficial ownership information (BOI) reports under the Corporate Transparency Act (CTA). The new deadline for filing BOI reports is March 21, 2025. The new deadline comes as a result of a ruling by the U.S. District Court for the Eastern District of Texas, which lifted a previous nationwide injunction that had prevented FinCEN from requiring reporting companies to file BOI reports. 

In response to the Court’s ruling, FinCEN announced the reinstatement of filing requirements as follows:

With the February 18, 2025, decision by the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336 (E.D. Tex.), beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again back in effect. However, because the Department of the Treasury (Treasury) recognizes that reporting companies may need additional time to comply with their BOI reporting obligations, FinCEN is generally extending the deadline 30 calendar days from February 19, 2025, for most companies.

It should be noted that the new filing deadline is subject to change. FinCEN explained in its February 18 notice that it “will provide an update before then of any further modification of this deadline, recognizing that reporting companies may need additional time to comply with their BOI reporting obligations once this update is provided.” In the absence of any modification of the deadline, companies should be advised to have their BOI reports filed by March 21, 2025.  

You can find more information about filing BOI reports here.