On March 2, 2025, the U.S. Treasury Department announced that it currently does not intend to enforce any penalties or fines associated with any current reporting deadlines under the Corporate Transparency Act (CTA) or the related reporting of beneficial ownership information (BOI). The Treasury Department has further indicated that it plans to issue a new proposed rule limiting the scope of enforcement to foreign reporting companies only. For domestic reporting companies and U.S. citizens, the Treasury Department noted that it will not enforce any fines or penalties even after a new rule comes into effect.

Prior to this decision, the U.S. District Court for the Eastern District of Texas entered a stay of its January 7, 2025 order enjoining the enforcement of the CTA, which had temporarily put the CTA back in effect. On February 19th, the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) issued further guidance on the CTA in connection with this ruling, indicating that the reporting requirement was back in effect with an extended deadline of March 21, 2025. However, in light of the Treasury Department’s decision this week, this deadline appears to no longer be in effect, and any further guidance will indicate the future reporting deadlines for foreign reporting companies exclusively.

Separately, on February 10, 2025, the U.S. House of Representatives passed the Protect Small Businesses from Excessive Paperwork Act 408 – 0, which extends the CTA filing deadline for all reporting companies to January 1, 2026. The bill is currently under review and awaiting vote by the Senate. If passed and signed by the President, the Excessive Paperwork Act will take effect immediately. Still, any enforcement of that deadline will remain subject to future rulemaking by FinCEN. FinCEN’s BOI reporting system appears to remain active, so businesses may choose to continue filing initial reports prior to any pending deadlines, but the deadlines themselves and the entities required to report will remain in flux until future rulemaking adds some clarity to the situation.

This article summarizes aspects of the law. This article does not constitute legal advice. For legal advice regarding your situation, you should contact an attorney.