The U.S. Treasury Department set the deadline for U.S. business entities to comply with the Corporate Transparency Act’s (CTA) beneficial ownership disclosure (BOI) requirements to March 21, 2025, the department’s Financial Crimes Enforcement Network (FinCEN) said earlier this week, though significant uncertainty regarding the requirements remains.

The announcement came Tuesday evening after the U.S. District Court for the Eastern District of Texas stayed the last remaining nationwide block against enforcement of the CTA, which had been successively enjoined throughout December and January, reported Bloomberg Law.

Additionally, the U.S. House of Representatives voted 408-0 on February 10 in favor of pushing the CTA’s reporting deadline to January 1, 2026. The Senate has yet to take action on the bill.

FinCEN wrote in a February 18 letter that “Notably, in keeping with Treasury’s commitment to reducing regulatory burden on businesses, during this 30-day period FinCEN will assess its options to further modify deadlines, while prioritizing reporting for those entities that pose the most significant national security risks. FinCEN also intends to initiate a process this year to revise the BOI reporting rule to reduce burden for lower-risk entities, including many U.S. small businesses.”

The requirements have been much litigated, with varying results. As Bloomberg Law noted, “District courts have been split on the issue. A federal court in Maine upheld the law as constitutional on Monday, and judges in Virginia, Michigan and Oregon all declined business’s requests for preliminary injunctions. But federal courts in Alabama and Texas obliged with the Texas court choosing to halt enforcement nationwide.”

NACS has filed briefs with the Fifth Circuit Court of Appeals urging the requirement to be blocked and is advocating that the Trump Administration further delay any requirements pending the litigation challenges. NACS will continue advocating that these requirements should not be placed on small businesses.