The Corporate Transparency Act is Back (For Now): Texas Court Lifts Final Nationwide Injunction Against the CTA

The Corporate Transparency Act (CTA) and its beneficial ownership information (BOI) reporting requirements are back in effect. On Monday, February 18, 2025, a federal district court in Texas granted a stay of the nationwide injunction previously issued in Smith, et al. v. U.S. Department of the Treasury, et al. As a result, there are now no legal impediments preventing FinCEN from enforcing the CTA. This ruling follows the U.S. Supreme Court’s recent decision staying a similar nationwide injunction in Texas Top Cop Shop, Inc. v. Garland, et al. 

FinCEN Announces Updated Deadlines

Recognizing that reporting companies may need additional time to comply, FinCEN has extended the BOI reporting deadline to March 21, 2025. This extension applies broadly, including to reporting companies who need to file an initial, updated or corrected BOI report.  BOI reporting for new companies or existing filers with new information must be filed going forward within 30 days. 

CTA Reporting Still Subject to Changes

Separately, on February 11, 2025, the U.S. House of Representatives passed a bill that would extend the filing deadline for entities formed before January 1, 2024, to January 1, 2026. While that bill now moves to the Senate, there is no guarantee of passage.

FinCEN itself acknowledged in its latest update that it too will assess options for further modifications, especially to revise the BOI reporting rule later this year to reduce compliance burdens for many U.S. small businesses.

Now is the Time to File

Given the current status, the time to complete your BOI reporting is now to ensure compliance with the law and its new deadlines.  We will continue to monitor both legislative and judicial developments affecting CTA compliance. Should you have specific questions about your reporting obligations, please do not hesitate to contact one of our Business and Finance attorneys.