The final nationwide injunction blocking enforcement of the Corporate Transparency Act (CTA) has been stayed, paving the way for the federal government to restart its implementation of the law. With the CTA back in effect, reporting companies should be ready to file their BOI reports by March 21, 2025.

In the case of Smith, et al. v. U.S. Department of the Treasury, District Court Judge Jeremy Kernodle explained that, following the Supreme Court’s recent ruling in the Texas Top Cop Shop matter, he would suspend his earlier nationwide injunction while the appeals process continues.

As a result, the federal government now has the green light to enforce the CTA. FinCEN has confirmed its intent to do so, noting that “beneficial ownership information (BOI) reporting obligations are once again in effect.”

FinCEN announced an extension of reporting deadlines following the ruling. For most reporting entities, the new deadline to submit an initial, updated, or corrected BOI report is now March 21, 2025. Entities formed or registered on or after February 18, 2025, must file within 30 days after formation or registration. And entities that were originally assigned a later deadline—for example, those benefiting from certain disaster relief extensions resulting in an April 2025 deadline—should continue to adhere to that later date.

FinCEN also communicated that further adjustments to reporting deadlines and requirements may be on the horizon. During the current 30-day extension period, the agency will “assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks.” Moreover, FinCEN intends to launch a review process later this year to revise the BOI reporting rule in order to lessen the burden on lower-risk entities, including many small U.S. businesses. 

While March 21st is a deadline reporting companies should work against, litigation continues across the country, and legislation that would amend, or outright eliminate, the CTA has been introduced in both the U.S. House and Senate. Given the track record on CTA implementation, don’t be surprised if there are more twists and turns ahead.