Beneficial ownership information (“BOI”) reporting under the Corporate Transparency Act has been reinstated after the nationwide injunction in the Smith case was stayed on February 17, 2025. For most reporting companies, the new deadline to file a BOI report is now March 21, 2025.

The U.S. Department of Treasury’s Financial Crimes Enforcement Network (“FinCEN”) is evaluating potential exemptions for so-called “low-risk entities” and assessing options to further modify deadlines (while prioritizing reporting for entities that pose the most significant risks to national security). However, FinCEN has not yet provided any details or additional guidance.

Although the House of Representatives has passed a bipartisan bill to extend the deadline to January 1, 2026, the Senate has yet to act. So, there is no guarantee that this extension will become law.

Accordingly, businesses should not rely on court rulings or pending legislation for relief. If the deadline holds, last-minute filers may face system overloads and risk penalties for late filings or non-compliance.

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