The suspended Beneficial Ownership Information (BOI) reporting deadline under the Corporate Transparency Act (CTA) has been reinstated, requiring most companies to file by March 21, 2025. This follows a February 18, 2025, court decision lifting a nationwide injunction that had paused enforcement since late 2024. 

Here’s what businesses need to know:

• Key Deadline: March 21, 2025
• Most reporting companies must submit initial, updated, or corrected BOI reports by this date.
• The 30-day extension from February 19, 2025, applies retroactively to entities with lapsed deadlines during the injunction period.

Exceptions and Extensions

• Disaster-affected companies: Businesses granted extensions due to federally declared disasters (e.g., hurricanes Beryl, Helene, or Milton) must follow their original later deadlines (e.g., April 2025).
• Exempt plaintiffs: Entities tied to National Small Business United v. Yellen(including its members as of March 1, 2024) remain exempt from reporting.

What’s Next?

• FinCEN may revise reporting rules later this year to ease requirements for lower-risk businesses, but March 21 remains binding unless updated.
• Congress is considering legislation (H.R. 736) to delay deadlines for pre-2024 entities to 2026, but the Senate has not yet acted.
• Companies should prepare to meet the March 21 deadline while monitoring for updates. Noncompliance risks penalties of $606 per day.