Update: Beneficial Ownership Information Reporting No Longer Enforced

On March 2, 2025, the Treasury Department announced that, for the time being, it will not be enforcing the March 21, 2025, deadline for Beneficial Ownership Information (BOI) reporting for domestic companies and U.S. citizens, nor will it impose any penalties or fines related to failure to report.

The Treasury has also announced that it’s preparing a rule to narrow the reach of the Corporate Transparency Act (CTA). Previously, all domestic and foreign companies were required to report. As revised, only foreign companies registered to do business in the U.S. would be required to file a report.

As we previously posted, the injunction suspending BOI reporting was most recently lifted on February 17, 2025 and thereafter the Treasury  announced a deadline of March 21, 2025, for all reporting companies that had not yet made their initial BOI report.

The Treasury has not indicated what will happen to the information provided by entities who’ve already reported under the CTA’s previous requirements. However, domestic companies and U.S. citizens are not required to update a previously submitted BOI report for their entity.

The CTA was first signed into law in 2021, and has experienced many challenges and criticisms since its adoption. We will continue to monitor the status of the CTA and related BOI reporting rule.

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Sadie E. Dupont

Business & Corporate Law Attorney at McCarty Law LLP
Sadie’s practice is focused primarily on business law matters, such as business formations, contract drafting, and mergers and acquisitions. She has an interest in observing and understanding the interconnectedness of the law with other business elements such as finance, marketing, management, sales, and operations.