Skip to content

CTA Back in Effect – Reports Now Due March 21

February 19, 2025

On Feb. 18, the U.S. District Court in Smith, et al v. U.S. Dept. of Treasury stayed the last remaining nationwide injunction on enforcement of the Corporate Transparency Act. After this court action, FinCEN announced that the Corporate Transparency Act (CTA) enforcement is back in effect. The new filing deadline for beneficial ownership reports (BOIR) for most companies is now March 21.

In its statement, FinCEN held open the possibility of providing additional time for BOIR reporting past March 21. As it stands now, however, existing companies have a deadline of March 21 to file their required BOIR reports. Going forward, new companies will have 30 days after the date of formation to file their initial BOIR. This is a shorter timeframe than the 90 days that was provided for companies formed in 2024. For companies that have an extended reporting deadline that is later than March 21 because of a natural disaster in their area, the later deadline will control.

This is likely not the last word on the CTA and filing deadlines. There are pending appeals court cases related to the constitutionality of the CTA before the Eleventh Circuit and Fifth Circuit. Congress is also considering a bill to extend the reporting deadline until 2026. Furthermore, in its statement, FinCEN held open the possibility of revisiting its rulemaking to make BOIR reporting less burdensome on “lower-risk entities, including many U.S. small businesses.”

Clark Hill’s CTA Task Force will continue to monitor for updates to the CTA and is available to counsel clients on reporting and compliance requirements.

This publication is intended for general informational purposes only and does not constitute legal advice or a solicitation to provide legal services. The information in this publication is not intended to create, and receipt of it does not constitute, a lawyer-client relationship. Readers should not act upon this information without seeking professional legal counsel. The views and opinions expressed herein represent those of the individual author only and are not necessarily the views of Clark Hill PLC. Although we attempt to ensure that postings on our website are complete, accurate, and up to date, we assume no responsibility for their completeness, accuracy, or timeliness.

Subscribe for the latest

Subscribe

Related

Event

2025 California Labor and Employment Law Symposium

Join Clark Hill for a full-day symposium exploring the most pressing legal issues facing California employers today. Our California Labor & Employment attorneys, along with colleagues from our Immigration and Cybersecurity/Data Privacy groups, will provide practical insights, legal updates, and strategic guidance across a range of workplace topics. Whether your role is in-house counsel, HR leadership, or company executive, this event is designed to equip you with the tools to help navigate California’s ever-evolving employment landscape.

Explore more
Event

Webinar: End of Year Privacy Check-In: What’s Changed, What Hasn’t and What’s Happening in 2026

Attendees will gain insights specific insight into the definition of ADMT under the new rules, common in-scope use cases and requirements, risk assessment and cybersecurity audit obligations and expectations for regulatory focus in 2026. You’ll walk away with a “check-list” of compliance priorities for 2026.

The session will provide practical guidance for legal, compliance, and business teams preparing for compliance deadlines and navigating emerging privacy risks.

Explore more
Event

2025 Illinois Labor & Employment Law Symposium

Join us for a complimentary half-day seminar designed for legal, HR, and business professionals navigating today’s rapidly changing work environment. Our experienced attorneys will share timely insights, practical strategies, and legal updates to help you stay compliant, mitigate risk, and lead with confidence.

Explore more