Latest CTA Update: BOI Deadline Pushed to January 13, Court Drama Continues

Here we go again.

On Monday, December 23, the U.S. Fifth Circuit Court of Appeals lifted the preliminary injunction that had halted enforcement of CTA reporting guidelines for nearly all privately held corporations, partnerships, and LLCs doing business in the U.S.

Shortly after the decision was announced, FinCEN – the agency tasked with enforcing the BOI reporting requirements – announced that it would push the original January 1 filing deadline back to January 13, 2025 for most filers.

Then last night (December 26), the Fifth Circuit issued yet another order that vacated its own stay of the injunction – meaning the injunction halting enforcement of BOI guidelines is back in effect for now. How long it stays that way is anyone’s guess, as the appeal has been expedited to the next available panel. Most observers expect enforcement to resume shortly. So if you haven’t submitted your BOI report yet, you still have a little over 2 weeks to do so.

A summary of key due dates are highlighted below:

• Reporting companies created or registered prior to January 1, 2024, have until January 13, 2025 to file.
• Reporting companies that were created or registered after September 4, 2024 that had a filing deadline between December 3, 2024 and December 23, 2024 also have until January 13, 2025.
• Reporting companies created or registered on or after December 3, 2024 and on or before December 23rd have an additional 21 days from their original deadline to file.
• Reporting companies that quality for disaster relief may have extended deadlines beyond January 13, 2025. These companies should abide by whichever deadline falls later.

For the very latest on the topic along with a complete listing of filing due dates, we encourage you to read the recent current update from FinCEN located in the Alert section at the top of the page.