CTA Timeline: A Full Legal History
The Corporate Transparency Act has had a turbulent regulatory history since going into effect in January 2024. This timeline covers key legislative, regulatory, and judicial events, from the law's enactment through the March 2025 Interim Final Rule that currently governs BOI reporting.
Only foreign reporting companies are required to file BOI reports with FinCEN under the Interim Final Rule. Domestic U.S. companies are currently exempt. This status may change, monitor this page for updates.
Foreign company filing deadline
Under the Interim Final Rule, foreign reporting companies that existed before the rule must file their initial BOI report with FinCEN by April 25, 2025, or within 30 days of qualifying in a U.S. jurisdiction. Corrections and updates are due within 30 days of the change.
CTA Interim Final Rule published
The CTA Interim Final Rule is published in the Federal Register. Only foreign reporting companies must file BOI reports; their reports do not include information on any U.S. persons.
Interim rule sent for publication
The government releases an interim "Rule" for publication that exempts all U.S. entities from CTA reporting, and exempts U.S. persons from providing BOI in any foreign entity's report. A 60-day comment period opens, which could bring further changes.
Treasury suspends penalties for domestic companies
The U.S. Department of the Treasury announces it will not enforce penalties or fines against U.S. citizens or domestic reporting companies, and plans rulemaking to narrow BOI reporting to foreign companies only. The CTA itself remains in effect.
FinCEN pauses enforcement pending new rule
FinCEN states it will not issue fines, penalties, or enforcement actions for missed BOI deadlines until a forthcoming interim final rule takes effect and its new deadlines pass — intending to issue that rule no later than March 21, 2025.
FinCEN sets a March 21 deadline
FinCEN again enforces the CTA and sets a new deadline of March 21, 2025 for entities formed before 2024 (and for any report otherwise due before that date), while noting further changes are possible.
Smith stay granted, enforcement resumes
The motion for a stay in Smith v. Treasury is granted, lifting the last nationwide injunction and allowing CTA enforcement to resume.
Plaintiffs respond in Smith v. Treasury
Plaintiffs file their response to the government's motion for a stay pending appeal, leaving the matter with the court.
Court orders expedited response
In Smith v. Treasury, the court orders plaintiffs to respond to Treasury's motion for a stay by February 14, 2025, signaling a prompt ruling.
DOJ appeals the Smith injunction
The Department of Justice files a Notice of Appeal in Smith v. Treasury and asks the district court to stay its injunction, reaffirming the view that the CTA is constitutional. FinCEN signals a 30-day deadline and review of "low-risk" entities.
FinCEN alert: reporting still voluntary
FinCEN notes that although the Supreme Court stayed the Texas Top Cop Shop injunction, a separate nationwide order in Smith v. Treasury remains in place — so companies are not required to file, though they may do so voluntarily.
Supreme Court stays the Texas injunction
The U.S. Supreme Court lifts the universal injunction issued by the Eastern District of Texas, allowing FinCEN to enforce the CTA, subject to the separate Smith order.
Government applies to the Supreme Court
The government files an application with the U.S. Supreme Court seeking to stay the nationwide injunction.
Fifth Circuit vacates its stay
The Court of Appeals vacates the stay pending oral argument, and FinCEN again suspends enforcement — BOI submissions become voluntary.
Fifth Circuit stays the Texas injunction
A Fifth Circuit motions panel stays the Texas injunction. FinCEN resumes enforcement and extends deadlines (e.g., pre-2024 entities to January 13, 2025).
CTA amendment floated, then withdrawn
A 1,500-page government funding bill includes an amendment to extend the deadline for pre-2024 entities to January 1, 2026. The bill is withdrawn the next day, and the eventual budget bill does not amend the CTA.
FinCEN suspends enforcement
In light of the Texas injunction, FinCEN suspends enforcement of the CTA but continues to accept filings on a voluntary basis.
Texas court issues nationwide injunction
The U.S. District Court for the Eastern District of Texas grants the National Federation of Independent Business a preliminary injunction, halting CTA enforcement nationwide.
Alabama court rules CTA unconstitutional
The U.S. District Court for the Northern District of Alabama enters a declaratory judgment for National Small Business United, finding the CTA unconstitutional. FinCEN appeals to the 11th Circuit and stops enforcing against NSBA members.
CTA goes into effect
BOI reporting requirements take effect. Companies formed before 2024 have until January 1, 2025 to file; companies formed in 2024 have 90 days after formation.
FinCEN issues the final BOI rule
FinCEN publishes the final rule implementing the CTA's beneficial ownership information reporting requirements.
CTA enacted
The Corporate Transparency Act is signed into law as part of the FY2021 National Defense Authorization Act, directing FinCEN to create a beneficial ownership registry.
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