Latimer LeVay Fyock, LLCLatimer LeVay Fyock, LLC

IMPORTANT CTA UPDATE: Corporate Transparency Act's Mandatory Reporting Deadlines Are Back in Effect. Most Covered Entities Must File by March 21, 2025

After a whiplash-inducing series of back-and-forth court orders, the federal Corporate Transparency Act’s (CTA) mandatory deadlines for reporting Beneficial Ownership Information (BOI) are once again back in effect. In what appears to be the final word on the issue for the foreseeable future, a recent court order means that most covered Reporting Companies will need to submit their BOI information to FinCEN by March 21, 2025, if they have not already done so.

As set forth in a February 18, 2025, FinCEN alert, the U.S. District Court for the Eastern District of Texas issued an order on that same date lifting a stay it issued on January 7, 2024, which placed BOI reporting requirements on hold. As such, according to FinCEN, “BOI reporting is now mandatory.”

However, FinCEN acknowledged “that reporting companies may need additional time to comply with their BOI reporting obligations,” which is why it is “generally extending the deadline 30 calendar days from February 19, 2025, for most companies.”

The new BOI reporting deadlines are now as follows:

  • For the vast majority of reporting companies, the new deadline to file an initial, updated, and/or corrected BOI report is now March 21, 2025. FinCEN will provide an update before then regarding 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.
  • Reporting companies that were previously given a reporting deadline later than the March 21, 2025, deadline must file their initial BOI report by that later deadline. For example, if a company’s reporting deadline is in April 2025 because it qualifies for certain disaster relief extensions, it should follow the April deadline, not the March deadline.

Reporting companies can report their beneficial ownership information directly to FinCEN for free using FinCEN’s E-Filing system, which is available here. More information is available at here.

We will continue monitoring developments and provide updates accordingly. But if you have yet to prepare and file your company’s BOI report (unless it qualifies for an exemption), time is running short to do so, and there are significant penalties for non-compliance. If you have questions or concerns about this court ruling or the CTA in general, please contact Latimer LeVay Fyock at your earliest convenience.