CTA Reporting Reinstated
Don’t Miss the March 21 Deadline

In our last update, we told you how the U.S. Supreme Court stepped in on January 23, 2025, lifting one of the key blocks on the CTA. That ruling temporarily reinstated the Beneficial Ownership Information (BOI) reporting requirements, but there was still a catch — another case, Smith v. U.S. Department of the Treasury, had a separate nationwide injunction in place, keeping the CTA’s rules on hold for everyone.

Well, that catch has now been cleared.

On February 18, 2025, the U.S. District Court for the Eastern District of Texas — in the Smith case — lifted the nationwide injunction that had been holding the CTA back. The very next day, on February 19, 2025, FinCEN announced that BOI reporting requirements are officially back in effect, with a new deadline of March 21, 2025, for most companies.

We know, another plot twist. But this time, it’s clear: The clock is ticking.

What This Means for Your Business

With the clock ticking toward the March 21, 2025 deadline, it’s time to get your Beneficial Ownership Information (BOI) report in order. Here’s what you need to know and do.

If your company falls under the CTA’s reporting requirements, you need to submit your BOI report to FinCEN before the March 21 deadline. This report includes key information about the individuals who own or control your business. Ignoring or delaying your filing could come with serious consequences:

• Civil Penalties: Over $500 per day for every day your report is late.
• Criminal Penalties: Willful violations can lead to fines up to $10,000 and two years in prison.

In short, waiting isn’t worth the risk.

Is There Hope for More Time? Maybe

There’s a chance the deadline could be extended, but it’s not guaranteed. Here's why:

• The U.S. House of Representatives passed the Protect Small Businesses from Excessive Paperwork Act (H.R. 736) unanimously on February 10, 2025, proposing to extend the BOI filing deadline to January 1, 2026, for companies formed before January 1, 2024.
• The bill was sent to the Senate on February 11, 2025, but so far, no action has been taken.

So, until the Senate acts, the March 21, 2025 deadline is still the law.

File Early and Stay Protected

Even with the possibility of an extension, now is not the time to relax. The rules are in effect, the penalties are steep, and the deadline is fast approaching. Getting your BOI report done now saves you the stress and risk later.

If you need help or have questions about what to file, we’re here to help you. Please email us at info@wilkinsonlawllc.com or call (732) 410-7595 for assistance.

At Wilkinson Law, we give business owners the clarity they need to fund, grow, protect, and sell their businessesTM. We are trustworthy business advisors keeping your business on TRACK: Trustworthy. Reliable. Available. Caring. Knowledgeable.®