Update: BOI Reporting Enforcement Halted

Update: The Corporate Transparency Act and its BOI reporting requirements are currently under litigation. Please refer to our most recent post for the latest developments.
On December 3, 2024, a Texas district court order placed a nationwide preliminary injunction on enforcement of the Corporate Transparency Act (CTA), placing the Beneficial Ownership Information (BOI) reporting requirement and its January 1, 2025 deadline on hold.
The Department of Justice filed a Notice of Appeal to the U.S. Court of Appeals for the Fifth Circuit on December 5, 2024, and either the Fifth Circuit or the U.S. Supreme Court could stay the district court’s order pending appeal.
In response, the Financial Crimes Enforcement Network (FinCEN) posted an alert saying that as long as the preliminary injunction remains in effect, reporting companies:
- are not required to report Beneficial Ownership Information (BOI) to FinCEN,
- will not be liable for failing to report their BOI, and
- may continue to voluntarily submit BOI reports.
If the Corporate Transparency Act (CTA) is ultimately upheld, BOI reporting requirements may be reinstated, so businesses should stay updated on legal and administrative developments.