Confused by the changing winds of the Corporate Transparency Act? Having trouble following the judicial drama? Aren’t we all! Below is a quick timeline of some of the key milestones and what they mean for filing requirements.

📘 Corporate Transparency Act: Key Enforcement Timeline

🔹 Jan 1, 2021
The Corporate Transparency Act (CTA) was enacted as part of the NDAA.
→ ⚠️ Unclear (Reporting rules still in development)

🔹 Sep 30, 2022
FinCEN published the final rule outlining who must report and what data is required.
→ ✅ Reporting Required (starting Jan 1, 2024)

🔹 Jan 1, 2024
CTA’s beneficial ownership reporting requirement officially takes effect; FinCEN’s system opens.
→ ✅ Reporting Required

🔹 Dec 3, 2024
A federal judge issues a nationwide injunction blocking enforcement of the CTA.
→ ❌ Not Required

🔹 Dec 23, 2024
Fifth Circuit stays the injunction, reinstating the CTA reporting rule temporarily.
→ ✅ Reporting Required

🔹 Dec 26, 2024
Appeals court vacates stay, reimposing the block on CTA enforcement nationwide.
→ ❌ Not Required

🔹 Jan 7, 2025
A second federal judge issues a separate injunction halting CTA enforcement.
→ ❌ Not Required

🔹 Jan 23, 2025
U.S. Supreme Court lifts one injunction, but another remains in effect.
→ ❌ Not Required

🔹 Feb 19, 2025
FinCEN announces a new March 21 deadline if injunctions are lifted.
→ ⚠️ Unclear

🔹 Mar 2, 2025
Treasury officially suspends BOI enforcement for all U.S. companies and citizens.
→ ❌ Not Required

🔹 Mar 21, 2025
FinCEN formally amends the rule: only foreign entities must report, excluding U.S. citizens.→ ❌ Not Required

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That's right. After all of that back and forth, US companies are no longer required to file a BOI report.