Reporting obligations imposed by the Corporate Transparency Act (“CTA”) have been reinstated, and reporting companies now must file their initial, updated or corrected beneficial ownership information (“BOI”) reports by Friday, March 21, 2025. However, FinCEN – the agency tasked with enforcement of the CTA – is currently considering whether to extend the filing deadline further for at least some reporting companies.
On February 18, 2025, a federal district court in Texas, where one of the court cases challenging the CTA is pending, granted a stay of the preliminary injunction that had previously halted the CTA’s enforcement. In response to this ruling, FinCEN announced a new filing deadline of March 21, 2025, that applies to the vast of majority of reporting companies (you can read the FinCEN update here). All BOI reports must be filed electronically with FinCEN as was previously the case.
FinCEN also stated that in the period leading up to March 21, 2025, it will assess whether to further modify deadlines to reduce the burden on businesses. In the future, FinCEN also intends to revise the BOI reporting rule to reduce the burden for lower-risk entities, including many U.S. small businesses.
Separately, the House of Representatives has recently passed a bill that would delay all CTA reporting until January 1, 2026. This bill will be considered by the Senate next. Other legislative efforts aimed at reducing or eliminating the compliance burden imposed by the CTA are also underway.
If you have questions about your situation, please reach out to your Tuthill & Hughes attorney to schedule a call. This alert is for information purposes only and does not constitute legal advice.