Alert: CTA-BOI Nationwide Injunction Lifted and FinCEN Announces Revised Reporting Deadlines

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The Supreme Court has granted the government’s motion to stay a nationwide injunction issued by a federal judge in the case of Texas Top Cop Shop, Inc., et al. v. Garland, et al., No. 4:24-cv-00478 (E.D. Tex.). However, a separate nationwide order, issued by a different federal judge in the case of Smith, et al. v. U.S. Department of The Treasury, et al., No. 6:2024cv00336 - Document 30 (E.D. Tex. 2025), remained in place, and reporting companies were not required to file beneficial ownership information with FinCEN despite the Supreme Court’s January 23 action in the Texas Top Cop Shop case.

On Tuesday, February 18, 2025, the U.S. District Court for the Eastern District of Texas lifted the nationwide injunction in the Smith, et al. v. U.S. Department of The Treasury, et al. case and the beneficial ownership information (BOI) reporting requirements under the Corporate Transparency Act (CTA) are once again in effect for most reporting companies.

FinCEN updated its alert (“Alert”) on February 19, 2025, acknowledging that in light of the District Court’s decision, reporting companies, except those specifically named in the Alert, are once again required to file beneficial ownership information with FinCEN. The Department of the Treasury acknowledged that reporting companies may need additional time to comply with their BOI reporting obligations, and accordingly extended the reporting deadline 30 calendar days from February 19, 2025, for most companies as follows:

  • For the vast majority of reporting companies, the new deadline to file an initial, updated, and/or corrected BOI report is now March 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 qualify for disaster relief may have extended deadlines that fall beyond March 21, 2025. These companies should abide by whichever deadline is later.

  • Plaintiffs in National Small Business United v. Yellen, No. 5:22-cv-01448 (N.D. Ala.) — namely, Isaac Winkles, reporting companies for which Isaac Winkles is the beneficial owner or applicant, the National Small Business Association, and members of the National Small Business Association (as of March 1, 2024) — are not currently required to report their beneficial ownership information to FinCEN at this time.


Further, in keeping with Treasury’s commitment to reducing regulatory burden on businesses, FinCEN, over the next 30-day period, will assess its options to further modify deadlines or reporting requirements for lower-risk entities, including many U.S. small businesses, while prioritizing reporting for those entities that pose the most significant national security risks.

In addition, there has been recent legislative development as efforts continue to seek a delay of the reporting deadline and on February 10, 2025, the House unanimously passed the Protect Small Businesses From Excessive Paperwork Act of 2025 (H.R. 736), which would delay the beneficial ownership information (BOI) mandatory reporting requirement due date to January 1, 2026, for entities formed prior to January 1, 2024. The bill has now been sent to the Senate.