On February 18, 2025, the U.S. District Court for the Eastern District of Texas stayed its nationwide preliminary injunction on beneficial ownership information (BOI) reporting under the Corporate Transparency Act (CTA). With the stay, the Eastern District of Texas aligns itself with the Supreme Court’s recent order in Top Shop, which granted a stay from another Texas judge’s order for a nationwide CTA injunction.
As a result, BOI reporting requirements are once again mandatory.
The Financial Crimes Enforcement Network (FinCEN) has extended the deadline for most reporting companies to file an initial, updated, and/or corrected BOI report to March 21, 2025. However, FinCEN has stated that it will “assess its options to further modify deadlines while prioritizing reporting for those entities that pose the most significant national security risks”.
Although most small businesses will still need to file initial BOI reports by the March 21 deadline, FinCEN has also announced that it plans to review reporting requirements at some point this year to reduce the regulatory burden on small business owners.
On the legislative front, a bill pending in Congress would extend the CTA reporting deadline until January 1, 2026, for reporting companies formed prior to January 1, 2024.
For now, entities should take steps to determine whether reporting requirements apply to their business and, if so, file a BOI report by March 21.
