Court of Appeals Lifts Pause on BOI Reporting Requirement
On December 23, 2024, the Court of Appeals lifted the temporary hold on the Beneficial Ownership Information (BOI) Reporting Requirement. Previously, the District Court for the Eastern District of Texas had issued a preliminary injunction to pause the BOI reporting mandate. However, the Department of Justice, representing the Department of the Treasury, filed a Notice of Appeal on December 5, 2024, and separately requested a stay of the injunction.
What Does This Mean for Businesses?
With the Court of Appeals staying the earlier order from the U.S. District Court for the Eastern District of Texas, the Corporate Transparency Act is now fully in effect. This means reporting companies are required to submit their Beneficial Ownership details to FinCEN immediately.
Updated Reporting Deadlines
To address the confusion caused by the preliminary injunction, FinCEN has updated the deadlines for reporting companies. Here are the revised deadlines:
| S.No | Scenario | Deadline |
| 1 | Companies created or registered before January 1, 2024 | January 13, 2025 |
| 2 | Companies created or registered in 2024 with original filing deadlines between December 3 and December 23, 2024 | January 13, 2025 |
| 3 | Companies created or registered in the U.S. between December 3, 2024, and December 23, 2024 | 21 days after the original filing deadline |
| 4 | Companies created or registered in the U.S. on or after January 1, 2025 | 30 days from the date of creation or registration |
Important Update: BOI Reporting is Required Again!
Beneficial Ownership Information (BOI) reporting requirements are back in effect following a recent court decision. Most companies must file by the new deadline of March 21, 2025.
Avoid penalties—file your BOI report with ease today!
Important Update: BOI Reporting is Required Again!
Beneficial Ownership Information (BOI) reporting requirements are back in effect following a recent court decision. Most companies must file by the new deadline of March 21, 2025.
Avoid penalties—file your BOI report with ease today!
Our Advice for Reporting Companies
There’s a strong chance of additional legal developments, as the plaintiff may appeal the Court of Appeals’ decision. Despite this uncertainty, the law is currently in force, and reporting companies should begin filing their BOI reports right away to avoid potential penalties.
Take steps now to ensure you meet your reporting obligations under the Corporate Transparency Act. FinCEN offers resources to help companies navigate the filing process, so be sure to use them to make compliance easier.
Disclaimer, Source, and reference
This content is for informational purposes only and does not constitute legal advice. It should not be used as legal evidence or cited in court proceedings.
FinCEN: FinCEN Website