On February 18, 2025, the nationwide injunction against enforcing the Corporate Transparency Act (CTA) was “stayed” by Eastern District Court Judge Jeremy Kernodle (citing the Supreme Court’s ruling in Texas Top Cop Shop), and FinCEN has stated (in a February 18, 2025 notice) that the deadline for most reporting companies to make required filings is now March 25, 2025. Although FinCEN did not explicitly so state, it appears the March 25, 2025 deadline applies to reporting companies formed or registered between January 1, 2024 and February 17, 2025. Reporting companies formed or registered on or after February 18, 2025, must file within 30 days from the date of creation or registration.

In its notice, FinCEN stated that, during the next 30 days, it “will assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks. FinCEN also intends to initiate a process this year to revise the BOI reporting rule to reduce burden for lower-risk entities, including many U.S. small businesses.”

The government is not expected to appeal Judge Kernodle’s ruling. The next ruling that could alter the status quo (absent legislation, executive order, or new FinCEN rule) is likely to be following the oral arguments scheduled to occur on March 25, 2025 in the Texas Cop Shop case.