We are providing an important update on the Corporate Transparency Act (CTA) and its Beneficial Ownership Information (BOI) reporting requirements, which affect both startups and established companies.
On February 18, 2025, the U.S. Supreme Court declined to intervene in Smith v. U.S. Department of the Treasury, effectively lifting the nationwide injunction that had paused enforcement of the CTA. As a result, FinCEN has announced that BOI reporting requirements are back in effect.
For most reporting companies, the new deadline to file initial, updated, or corrected BOI reports is now March 21, 2025. Companies with later deadlines, such as those qualifying for disaster relief extensions, may still file by their original deadlines.
FinCEN has indicated that the March 21 deadline may be adjusted and plans to review potential extensions, particularly for small businesses, over the next 30 days.
Meanwhile, the U.S. House of Representatives recently passed the Protect Small Businesses from Excessive Paperwork Act of 2025, which, if enacted, would extend the BOI filing deadline to January 1, 2026. The bill is now under Senate consideration.
With reporting requirements reinstated, businesses should prioritize compliance. We are closely monitoring further developments and are available to assist with filing obligations.
