The U.S. District Court for the Eastern District of Texas has issued a stay of its previous injunction of The Financial Crimes Enforcement Network (FinCEN)’s mandatory filing of Beneficial Ownership Information (BOI). As a result, BOI reporting requirements under the federal Corporate Transparency Act (CTA) are once again back in effect and mandatory.

Updated Deadlines

  • For the vast majority of reporting companies, the new deadline to file an initial, updated, and/or corrected BOI report is now Mar. 21, 2025. FinCEN will provide an update before then of any further modification of this deadline, recognizing that reporting companies may need additional time to comply with their BOI reporting obligations once this update is provided.
  • Reporting companies that were previously given a reporting deadline later than Mar. 21 must file their initial BOI report by that later deadline. For example, if a company’s reporting deadline is in April 2025 because it qualifies for disaster relief extensions, it should follow the April deadline.
  • Reporting companies formed or registered on or after Feb. 18, 2025, must file within 30 days from their creation/registration date.

Additional information is available on FinCEN’s website: Beneficial Ownership Information Reporting | FinCEN.gov,

As a reminder, companies required to report BOI include:

  1. A corporation, a limited liability company (LLC), or company otherwise created in the U.S. by filing a document with a secretary of state or any similar office under the law of a state or Indian tribe; or
  2. A foreign company registered to do business in any U.S. state or Indian tribe.

Twenty-three types of entities are exempt, including publicly traded companies, nonprofits, and certain large operating companies. A full list of exemptions is available in the FAQ section (item C.2) of FinCEN’s website or within FinCEN’s Small Entity Compliance Guide.

If you have questions about this development or anything related to your rights regarding CTA requirements, the BOI reporting process, or business law in general, feel free to contact the Colligan Law team at 716- 885-1150 for assistance.