Corporate Transparency Act Back in Effect – Deadline for Compliance Pushed to March 21, 2025

By: Marian A. Kornilowicz and Christopher A. Ouellette

The implementation of the Corporate Transparency Act (CTA) has faced multiple legal challenges over the past few months, leading to shifting compliance deadlines. An initial injunction halted reporting requirements, prompting the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) to extend the deadline for Beneficial Ownership Information (BOI) reports to January 13, 2025. Subsequent court rulings reinstated and then paused enforcement again, creating uncertainty for businesses.

Now, with the U.S. Supreme Court and the U.S. District Court for the Eastern District of Texas staying the injunctions, BOI reporting requirements are back in effect. FinCEN has set a new compliance deadline of March 21, 2025, for most reporting companies. While FinCEN has indicated in its February 19, 2025 notice that it may reevaluate reporting requirements for certain “low-risk entities,” primarily small businesses, no formal changes have been made.

Even though there continue to be legal challenges to the CTA, with filing requirements and the penalties for not filing back in effect, it is important for business owners to get the necessary information together and submit their reports by the new deadline. Cohen Seglias’ Business Transactions Group is available to assist clients in complying with the CTA, and the preparation and filing of the BOI reports. Please reach out to a member of our team with any questions regarding CTA compliance.