Corporate Transparency Act Reporting Resumes

What Happened?

On February 19, 2025, the Financial Crimes Enforcement Network (FinCEN) of the U.S. Treasury Department issued a notice confirming the resumption of reporting requirements under the Corporate Transparency Act (CTA). This follows the lifting, on February 18, 2025, of the last nationwide injunction that had blocked enforcement of the CTA.

What is the New Reporting Deadline?

FinCEN has extended the CTA reporting deadlines to March 21, 2025, to account for the delays caused by the injunction. Every reporting company needs to comply with this deadline.

The FinCEN notice also suggests that further adjustments to the reporting deadlines may be made to reduce the burden on low-risk entities, including many small businesses. Additionally, a bill currently under consideration in Congress seeks to extend the reporting deadline to January 1, 2026. However, this bill has not yet passed the Senate and has not been signed into law.

What are the CTA Reporting Requirements? 

As a reminder, the CTA requires all reporting companies to file a report identifying their beneficial owners. A “reporting company” typically refers to any U.S. entity formed through state registration, such as limited liability companies (LLCs) and corporations. For CTA purposes, a beneficial owner is defined as any individual who directly or indirectly (i) owns 25% or more of the entity, or (ii) exercises substantial control over it. Failure to comply with CTA reporting requirements may result in significant penalties, including fines and potential imprisonment.

How is Bernstein Shur Helping Clients Comply with the Corporate Transparency Act?

Our Business Law Practice Group has been closely monitoring the CTA since it was enacted and is ready to assist you. If you have any questions about whether or when you need to file a report, our interdisciplinary business law team is ready to help. Contact your Bernstein Shur attorney or Bryce Morrison at bmorrison@bernsteinshur.com.