Beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act are back in effect.  BOI reporting is again mandatory.  The United States Supreme Court lifted the nation-wide injunction issued in the case of Texas Top Shop, Inc. v. Garland on January 23, 2025 (E.D. Tex).  In response to this stay, Judge Kernodle of the U.S. District Court for the Eastern District of Texas lifted his stay in the case of Smith et. al. v. U.S. Department of the Treasury, et al on February 18, 2025 until the appeal process is completed.  As a result, FinCEN is generally extending the deadline 30 calendar days from February 19, 2025 for most companies.

For the majority of reporting companies the new deadline to file an initial, updated and/or corrected BOI report is now March 21, 2025.  This deadline may be further modified by FinCEN.  Reporting companies that were previously given a reporting deadline later than the March 21, 2025 deadline should report by the later deadline.  An example is qualifications for certain disaster relief extensions (Hurricanes Milton, Helene, Debby, Beryl and Francine).

This new announcement does not impact the stay from currently filing BOI reports for the National Small Business Association or members thereof as a result of ongoing litigation in the case styled National Small Business United v. Yellen (N.D. Ala.)

Most importantly, FinCEN announced today that it intends to initiated a process this year to revise the BOI reporting rule to reduce burden for lower-risk entities, including many U.S. small businesses.