The U.S. District Court for the Eastern District of Texas has reinstated the beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) as of February 18, 2025. This decision means that affected entities must once again comply with BOI reporting obligations. However, recognizing that businesses may need additional time, the Financial Crimes Enforcement Network (FinCEN) is providing a general extension of 30 calendar days, moving the deadline to March 21, 2025, for most reporting companies.

Key Deadlines and Compliance Updates

New Filing Deadline:
For the majority of reporting companies, the initial, updated, or corrected BOI report must now be submitted by March 21, 2025. FinCEN may further modify this deadline and will provide updates if additional time is granted.

Later Deadlines Apply for Certain Companies:
If a company was previously assigned a reporting deadline after March 21, 2025 (e.g., due to disaster relief extensions), that later deadline remains applicable. Companies qualifying for such extensions should follow the original timeline provided to them.

Compliance and Reporting Process

Businesses must submit their BOI reports via FinCEN’s E-Filing system, available free of charge at https://boiefiling.fincen.gov. More details and compliance resources can be accessed at fincen.gov/boi. Contact your Boyum advisor if you have any questions.

Background on the Legal Proceedings

On January 7, 2025, the Eastern District of Texas had issued a stay on FinCEN’s BOI reporting regulations, preventing enforcement of the CTA’s requirements. However, the U.S. Department of Justice appealed this decision on February 5, 2025, and requested a stay on the order during the appeal process. On February 18, 2025, the court granted this request, meaning that FinCEN’s BOI reporting regulations are once again in effect until the appeal is resolved.