Nationwide Injunction of Corporate Transparency Act Reporting Requirements and Enforcement Lifted

The nationwide injunction of the Corporate Transparency Act (CTA) was lifted by the U.S. District Court in Smith v. U.S. Department of the Treasury. This follows the U.S. Supreme Court’s lifting of an earlier nationwide stay in a separate case, Texas Top Shop Cop, Inc. v. Garland. These decisions reinstate the filing and reporting requirements of all Reporting Companies under the Corporate Transparency Act.

On February 19, 2025, FinCEN issued an alert that all Reporting Companies with filing deadlines falling during the previous injunction period must file the required information by March 21, 2025.

While FinCEN has previously indicated it would evaluate whether future deadline extensions are necessary and legislation that may impact reporting requirements and deadlines could be enacted by Congress and signed by the President, entities should reengage with counsel and work toward filing the required information without delay prior to the March 21, 2025 deadline.