All non-exempt entities that would have previously had filings due are required to complete their filings by March 21, 2025.
The Corporate Transparency Act's beneficial ownership information (BOI) reporting requirements are once again back in effect following a February 18, 2025 court decision. The deadlines for filing initial, updated, and/or corrected BOI reports are currently as follows:
- For most non-exempt entities, the new filing deadline is March 21, 2025, which is 30 calendar days from February 19, 2025.
- Reporting entities that were previously given a reporting deadline later than the March 21, 2025 deadline must file their initial BOI report by that later deadline. For example, if an entity's reporting deadline is in April 2025 because it qualifies for certain disaster relief extensions, it should follow the April deadline, not the March deadline.
- For newly formed entities, the deadline for an initial filing is the later of March 21, 2025 or 30 days after formation.
A reminder that you can file BOIRs using the relatively straightforward BOI E Filing System. You can find resources relating to CTA compliance in the Lathrop GPM CTA Client Resource Center, including our Six-Step Guide to BOI Reporting.
We will continue to monitor CTA developments, especially because FinCEN has indicated that it is committed to reducing regulatory burdens on businesses and will assess its options to further modify deadlines and ongoing legislative activity in Congress targeted to provide for additional extensions. However, absent additional extensions by FinCEN, the deadlines are currently as indicated above.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
