CTA Update: Court Halts Enforcement of BOI Requirements, Deadline in Limbo

On Tuesday, December 3, the U.S. District Court for the Eastern District of Texas granted a nationwide preliminary injunction enjoining enforcement of CTA reporting requirements and putting a stay on the January 1, 2025 compliance deadline. While the government quickly filed an appeal, FinCEN – the agency tasked with enforcing the BOI reporting requirements – announced that it would comply with the injunction as long as it remains in effect.

What does that mean for you and your company? The short answer is, you are not required to file beneficial ownership information with FinCEN while the injunction remains in effect. If and when it is lifted is anyone’s guess. But in the meantime, FinCEN welcomes companies to voluntarily submit their BOI reports as originally called for by January 1.