---
url: 'https://www.fmjlaw.com/cta-update-boi-reporting-is-back-with-new-deadlines-for-compliance/'
title: 'CTA UPDATE: BOI Reporting is Back with New Deadlines for Compliance'
author:
  name: Adam
  url: 'https://www.fmjlaw.com/author/adam-brownfmjlaw-com/'
date: '2025-02-20T20:41:45+00:00'
modified: '2025-02-20T22:29:15+00:00'
type: post
summary: 'Current reporting deadline now set for March 21, 2025.'
categories:
  - Legal Alert
  - Thought Leadership
tags:
  - BOI
  - BOI Reporting
  - CTA
published: true
---

# CTA UPDATE: BOI Reporting is Back with New Deadlines for Compliance

# The current reporting deadline is now set for March 21, 2025.

## In Summary

A Texas federal judge stayed his order barring enforcement of the CTA’s BOI reporting requirements. In response, the Department of the Treasury announced that most companies are required to comply with BOI reporting by **March 21, 2025**. The CTA’s status could change yet again, but if you have an LLC or other business entity, you will likely be required to meet these new deadlines.

## The Latest Litigation Development

Earlier this week, in *Smith, et al. v. United States Department of the Treasury, et al.*, 6:24-cv-00336 (E.D. Tex.), a Texas federal judge stayed his preliminary injunction barring the federal government from enforcing the CTA. That preliminary injunction was – at least for the moment – the only legal obstacle preventing the government from continuing to enforce the CTA. Now that the injunction is stayed, the CTA is back in effect while the *Smith *case and other CTA cases are on appeal.

## FinCEN’s New Deadlines

In response to the ruling, the Department of the Treasury’s FinCEN department issued a notice setting new deadlines for CTA compliance. Most importantly, FinCEN announced that “[f]or the vast majority of reporting companies, the new deadline to file an initial, updated, and/or corrected BOI report is now March 21, 2025.” You can find FinCEN’s official notice [here](https://fincen.gov/sites/default/files/shared/FinCEN-BOI-Notice-Deadline-Extension-508FINAL.pdf).

## Could the CTA’s Status Change Yet Again?

If you have followed this saga over the last few months, you have seen the CTA’s legal status change several times as the courts work through lawsuits challenging the legislation. You should assume that you will be required to comply with FinCEN’s new deadlines. But we cannot promise with certainty that the CTA’s status won’t change for at least a couple of reasons.

First, it’s possible another plaintiff will file a similar federal lawsuit in another court and obtain a separate preliminary injunction barring CTA enforcement. That injunction, if issued, would likely be stayed before too long, but it could remain in effect long enough to require FinCEN to alter the compliance deadline yet again.

Second, it’s possible that the Trump Administration may change the government’s approach to enforcing the CTA or defending it in court. Over the last several weeks, the Trump Administration has abruptly adopted new policies in a host of different areas of federal law enforcement. We cannot rule out the possibility that the Administration makes a similar decision about the CTA.

FMJ is continuing to monitor the situation. If you have questions about Corporate Transparency Act compliance, FMJ attorneys are here to assist. Please contact [Pat Shriver](https://www.fmjlaw.com/professional/ernest-pat-shriver/) or [Brad ](https://www.fmjlaw.com/professional/bradley-r-hutter/)[Hutter](https://www.fmjlaw.com/professional/bradley-r-hutter/) with your questions.

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