Corporate Transparency Act Reporting Requirements Take Effect on March 21, 2025

Most small business owners must file a Beneficial Ownership Information Report ("BOIR") with the Financial Crimes Enforcement Network ("FinCEN") by March 21, 2025, to comply with the Corporate Transparency Act ("CTA"). This requirement follows recent court decisions that removed previous legal barriers to enforcement.

On February 17, 2025, the U.S. District Court for the Eastern District of Texas (the "Eastern District") lifted its injunction in Smith v. United States Department of the Treasury, et al. This injunction had previously blocked the enforcement of the CTA on constitutional grounds. The decision came after the U.S. Supreme Court lifted a separate injunction in McHenry v. Texas Top Cop Shop, Inc., another case challenging the CTA. With these rulings, no remaining legal restrictions are currently preventing FinCEN from enforcing the reporting requirements.

Following the Eastern District’s decision in Smith, FinCEN announced the March 21, 2025, deadline, recognizing the need for additional time for reporting companies to comply with BOIR filing requirements.

Smith and McHenry will continue to be litigated in the coming months, meaning that CTA reporting requirements could change again depending on future court rulings. Additionally, some lawmakers have proposed legislation that could extend filing deadlines or exempt certain small businesses from compliance. However, at this time, no legislative changes have been enacted. We will provide updates if any modifications to the reporting obligations occur.

For now, small business owners should assume that the current March 21, 2025 deadline remains in effect and take necessary steps to comply.

If you have any questions about CTA compliance or need assistance filing your BOIR, contact a DeWitt Business Attorney today to ensure your business meets its reporting obligations on time.