Corporate Transparency Act Reporting Requirements Back in Effect with Extended Reporting Deadline; FinCEN Announces Intention to Revise Reporting Rule

Following the February 18, 2025, decision by the U.S. District Court for the Eastern District of Texas in Smith, et al. v. U.S. Department of the Treasury, et al., 6:24-cv-00336, the Financial Crimes Enforcement Network (FinCEN) has announced that beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act are back in effect, with a new deadline of March 21, 2025 for most companies.

FinCEN has also announced that it will assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks. FinCEN 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.

Stay tuned. The Trump administration has generally taken the position that the Corporate Transparency Act’s beneficial ownership information reporting requirements are enforceable, and will look at options “to prioritize reporting for those entities that pose the most significant national security risks while providing relief to lower-risk entities.”

Further, FinCEN has stated there may be further changes to the reporting deadline as it will assess available options to modify deadlines under the law.

Lastly, the House unanimously passed a bill last week that would push the reporting deadline for most entities to January 1, 2026. The Senate has not yet taken action.