A federal appeals court Dec. 23 issued a ruling reinstating reporting requirements under the Corporate Transparency Act (CTA), with the Treasury Department’s FinCEN extending key deadlines to accommodate the recent legal uncertainty.
The U.S. Court of Appeals for the Fifth Circuit stayed a preliminary injunction that had temporarily blocked the law’s enforcement. Under the revised timeline, companies created or registered before Jan. 1, 2024, now have until Jan. 13, 2025, to file their initial beneficial ownership information (BOI) reports with FinCEN. Previously, they were required to file by Jan. 1, 2025.
FinCEN also announced other revised reporting deadlines:
- Created on or after Sept. 4 with original filing deadline from Dec. 3-23: New deadline of Jan. 13, 2025.
- Created from Dec. 3-23: These companies have an additional 21 days from their original filing deadline, which is 30 days from actual or public notice that the company’s creation or registration is effective.
- Created on or after Jan. 1, 2025: 30 days to after receiving actual or public notice that their creation or registration is effective.
- Qualifying for disaster relief: May have extended deadlines that fall beyond Jan. 13, 2025; they should abide by whichever deadline is later.
Under the CTA, it’s estimated that more than 30 million U.S.-based corporate entities are required to file BOI reports with FinCEN — though many exemptions exist. This week’s Fifth Circuit ruling comes just a few weeks after a Texas court struck down the law, which passed with bipartisan support and over a presidential veto, as unconstitutional, finding that Congress exceeded its authority.
