New filing deadline Friday, March 21, 2025
Reporting under the federal Corporate Transparency Act (CTA) and related regulations has been variously paused and reinstated over the last several months due to ongoing litigation in multiple federal courts throughout the country. The latest iteration of this stop-and-go saga arrived on February 17, 2025, in the form of a court order by the U.S. District Court for the Eastern District of Texas staying its previous order from January 7, 2025, that paused mandatory CTA reporting. Smith, et al. v. U.S. Dep’t of Treas., et al., Civil Action No. 6:24-cv-336-JDK (E.D. Tex.).
As a result, CTA reporting is once again mandatory. On February 18, 2025, the Financial Crimes Enforcement Network (FinCEN), the U.S. Treasury agency responsible for implementing the CTA, circulated a notice extending the deadline for mandatory reporting under the CTA to Friday, March 21, 2025. The new deadline applies to all reports – initial, updated, and corrected – that would have been due on or prior to March 21, 2025, if reporting had not been suspended.
Reporting companies that would otherwise have a reporting deadline after March 21, 2025 – such as a company that qualified for certain disaster relief reporting extensions – may adhere to the later deadline.
In its notice, FinCEN indicated that it will consider whether the March 21 deadline should be extended further for certain reporting companies, and whether FinCEN should revise the reporting rule more generally “to reduce the regulatory burden on lower-risk entities, including many U.S. small businesses.” FinCEN committed to providing notice of any deadline extension prior to the March 21 deadline, and signaled that many other revisions to the reporting rule would be initiated in 2025.
As we predicted last month when reporting was paused, CTA reporting is again mandatory and reporting companies now have a relatively short window to comply. We will continue to stay on top of CTA news and update our website as it develops.
Related articles: Corporate Transparency Act Compliance Voluntary, Corporate Transparency Act Enforcement Enjoined Nationwide, Ready or Not: Corporate Transparency Act Compliance is Coming, FinCEN Issues Final Rules for the Corporate Transparency Act Reporting Requirements – Significant Changes Coming to Corporate Reporting for Alaska Companies
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