CTA Reporting is Back (Yet Again): New March 21, 2025 Deadline
Following a federal court ruling, Beneficial Ownership Information (BOI) reporting under the Corporate Transparency Act (CTA) is yet again back in effect.
The U.S. District Court for the Eastern District of Texas in Smith v. U.S. Department of the Treasury lifted its stay on FinCEN’s BOI reporting requirements on February 18, 2025. This means that companies generally must comply with the CTA’s reporting rules absent a further change.
To partially address the regulatory burden, the Department of the Treasury and FinCEN now have delayed the reporting deadline for most covered companies to March 21, 2025.
What This Means for Your Company
BOI Reporting is Once Again Mandatory – All covered companies must comply.
Most companies now have until March 21, 2025 to file.
Further Deadline Modifications Possible – There have been hints that deadlines could be adjusted again but there is no guarantee.
Potential Legislative Changes – Pending federal legislation (H.R. 736) could extend the reporting deadline to next year, but it remains under review by the Senate Banking Committee and is not guaranteed to pass.
What to Do
Determine Whether You Have a Reporting Obligation
Does your company qualify as a reporting company under the CTA?
If so, currently you must file a BOI report with FinCEN before your deadline.
Gather the Required Information
Identify beneficial owners and company applicants.
Collect names, birthdates, addresses, and government-issued IDs.
File Before March 21, 2025
Use FinCEN’s E-Filing System at https://boiefiling.fincen.gov.
Monitor Regulatory and Legislative Developments
Pending legislation (H.R. 736) could extend the deadline to next January, but there is no certainty it will pass.
FinCEN could adjust deadlines again—stay informed.
Bottom Line:
BOI reporting is back in effect.
Deadline for most companies: March 21, 2025. Do not wait until the last minute to assess and file if you determine appropriate.
Need More information? Contact Troy Garris at troy@garrishorn.com.