On February 19, 2025, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) announced on its website that beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are back in effect.
For most reporting companies, the new deadline for filing an initial, updated or corrected BOI report is March 21, 2025.
Notably, FinCEN also states in its website notice:
- that, “in keeping with Treasury’s commitment to reducing regulatory burden on businesses, during this 30-day period, FinCEN will assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks;”
- that “FinCEN will provide an update before [March 21, 2025] 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;” and
- that “FinCEN also intends to initiate a process this year to revise the BOI reporting rule to reduce burden for lower-risk entities, including many U.S. small businesses.”
Additionally, numerous lawsuits challenging the constitutionality of the CTA are still pending, and legislation has been proposed in Congress to extend the filing deadline for certain BOI reports or to outright repeal the CTA.
In sum, the future of the CTA remains uncertain.
Despite such confusion and uncertainty, reporting companies would be well-advised to begin, or to restart, their preparations to file required BOI reports by the current deadline of March 21, 2025, pending any new developments in the matter.
Explore our recent article outlining the resources available to assist in complying with the Corporate Transparency Act.