CTA Is Mandatory / Deadline March 21

On February 18, 2025, the U.S. District Court for the Eastern District of Texas eliminated the Smith nationwide injunction. In response, the Financial Crimes Enforcement Network (FinCEN) announced the Corporate Transparency Act (CTA) beneficial ownership information (BOI) reporting requirements are mandatory again. The new deadline is March 21, 2025.

FinCEN also announced it intends to initiate a process in 2025 “to revise the BOI reporting rule to reduce burden for lower-risk entities, including many U.S. small businesses.” Additionally, FinCEN may further change deadlines between now and March 21, 2025 as FinCEN prioritizes BOI reporting “for those entities that pose the most significant national security risks.”

FinCEN did not define “lower-risk entities” or “entities that pose the most significant national security risks”.

Next Steps

There is no further update regarding Congress seeking to extend the deadline to January 1, 2026. We also do not know if or when FinCEN will actually change the March 21, 2025 deadline. I recommend you assume that March 21, 2025 is the deadline.