Corporate Transparency Act Injunction Pauses BOI Filing Requirements

In December, a federal court issued a Corporate Transparency Act injunction, temporarily halting the enforcement of Beneficial Ownership Information (BOI) report filing requirements. This development has left many small business owners wondering, “Is BOI still required?” Because of recent developments, the answer is yes.

On February 17, 2025, a Texas Federal Judge lifted the final remaining nationwide injunction on enforcement of the Corporate Transparency Act. This means the Beneficial Ownership Information Report is required again, and the new deadline to file is March 21, 2025.

Here’s what you need to know about the injunction, the BOI filing requirements, and what could happen next.

On December 3, 2024, a federal court in Texas granted a nationwide preliminary injunction halting the enforcement of the Corporate Transparency Act’s reporting requirements, thereby making BOI report filing optional pending further legal proceedings. But the injunction against the CTA has been lifted now, meaning that BOI reporting is again required.

What the Injunction Means for BOI Filing Requirements

The Corporate Transparency Act (CTA) was designed to combat financial crimes like money laundering by requiring certain businesses to disclose their beneficial owners to the Financial Crimes Enforcement Network (FinCEN). Beneficial owners are individuals who own at least 25% of a company or have substantial control over it. The BOI filing requirements took effect in 2024, but the CTA injunction has put them on hold. 

This injunction meant that businesses temporarily didn’t have to file BOI reports while legal challenges to the CTA were being resolved. However, the injunction has now been lifted.

Is BOI still required?

Yes, BOI filing is now required. Still, businesses should remain prepared for possible changes. Staying informed about these developments is crucial for small business owners.

Why the Injunction Was Issued

The court’s decision to issue the Corporate Transparency Act injunction stems from ongoing legal debates about the scope and impact of the BOI filing requirements. Critics argue that the reporting rules place an undue burden on small businesses, many of which lack the resources to navigate complex compliance obligations.

What is the BOI report?

The BOI report is a key component of the CTA. It requires certain businesses to disclose information about the business and the owners. Each owner will need to provide:

• Their legal name
• Date of birth
• Current address (residential address or business address)
• An identification number from a non-expired document like a U.S. passport, state ID, or foreign passport
• An image of that ID

The BOI report also asks for the following information about the company: 

• The full legal business name
• Any trade name or DBA the business holds
• Current business address (must be in the U.S.)
• Jurisdiction where the business was formed
• Taxpayer identification number (foreign reporting company) or employer identification number (domestic reporting company)

Not all businesses are subject to BOI filing requirements. For example, publicly traded companies and financial institutions are exempt from BOI reporting. Small business owners should verify whether their entity type is required to file. 

What should you do now?

Here’s how to stay ready for possible changes to the BOI filing requirements:

• Stay informed: Follow trusted sources like FinCEN for updates about the CTA and BOI requirements.
• Gather your information: If you haven’t already, collect details about your business’s beneficial owners.
• Work with trusted partners: ZenBusiness can help you navigate compliance and stay prepared for whatever comes next.

How ZenBusiness Helps You Prepare for Compliance

At ZenBusiness, we understand that legal compliance can be confusing and stressful. That’s why we offer our Beneficial Ownership Information Filing Service. With this service, we guide you through the process of BOI reporting so that you’ll have the peace of mind of knowing you’re in compliance. With ZenBusiness, you can focus on growing your business while we handle the complexities of compliance.

Disclaimer: The content on this page is for information purposes only and does not constitute legal, tax, or accounting advice. If you have specific questions about any of these topics, seek the counsel of a licensed professional.