The Financial Crimes Enforcement Network of the U.S. Treasury Department (FinCEN) announced a new deadline for most companies covered by the Corporate Transparency Act (CTA). Such reporting companies now must file Beneficial Ownership Information (BOI) reports no later than March 21, 2025.

FinCEN made its announcement on February 18, 2025, in response to a decision by a federal judge in the U.S. District Court for the Eastern District of Texas lifting the preliminary injunction in Smith v. United States Department of the Treasury. That decision removed the last judicial impediment to the enforcement of the CTA. With limited exceptions for certain reporting companies qualifying for an extension due to disaster relief or who may be subject to an exception as a plaintiff in National Small Business United v. Yellen, reporting companies should file their BOI reports no later than March 21, 2025. As of today, the deadline appears firm and should be considered binding. However, in its announcement, FinCEN left itself the option of extending the deadline if it determines an extension is warranted, indicating that it would provide an update of any modification of the March 21, 2025, deadline prior to that date, recognizing companies impacted by this announcement may need additional time to comply with their BOI reporting obligations.

In light of the March 21, 2025, time frame, companies should take heed of this decision and make every effort to meet this reporting deadline.