The nationwide injunction blocking the Corporate Transparency Act (CTA) Beneficial Ownership Information (BOI) reporting requirement has been lifted. As of February 18, 2025, most reporting companies must comply with FinCEN’s BOI reporting rules. This decision comes after the U.S. District Court for the Eastern District of Texas lifted the Smith, et al. v. U.S. Department of The Treasury, et al. case injunction, effectively reinstating the BOI filing obligations for most businesses.

Updated Reporting Deadlines

To allow businesses additional time to comply, FinCEN has extended the reporting deadline by 30 calendar days from February 19, 2025.

Here’s what you need to know:

• New Deadline: March 21, 2025, is now the filing deadline for most reporting companies to submit initial, updated, or corrected BOI reports.
• Disaster Relief Extensions: Businesses qualifying for disaster relief may have additional time beyond March 21, 2025, based on their circumstances.

Failure to Comply: Potential Penalties and Fees

Businesses failing to meet the BOI reporting requirements could face serious consequences, including:

• Civil penalties of up to $606 per day for each day a violation continues.
• Criminal penalties, including fines up to $10,000 and/or imprisonment for up to two years for willful non-compliance or providing false information.

What Businesses Should Do Now

With the reinstatement of BOI reporting requirements, businesses should act quickly to ensure compliance:

• Determine if your company is a reporting entity under CTA rules.
• Gather required beneficial ownership information for submission.
• File with FinCEN by March 21, 2025, unless exempt.
• Monitor FinCEN updates in case of further deadline modifications.

Potential Deadline Extensions for Small Businesses

Regulatory efforts to ease the burden on small businesses continue. FinCEN is currently reviewing options to modify deadlines or reporting requirements for lower-risk entities, such as small businesses. Additionally, a new bill—the Protect Small Businesses from Excessive Paperwork Act of 2025 (H.R. 736)—has been unanimously passed by the House. If approved by the Senate, this legislation would push the reporting deadline to January 1, 2026, for entities formed before January 1, 2024.

Need assistance?

Contact me or legal counsel to ensure compliance and avoid penalties.