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The U.S. Court of Appeals for the Fifth Circuit on Monday reinstated the enforceability of the Corporate Transparency Act and lifted the nationwide injunction issued by the district court judge earlier this month.
In the process, the court reinstated the Jan. 1, 2025, compliance deadline for most covered businesses to report their beneficial ownership information to the Financial Crimes Enforcement Network as required by the CTA.
Due to the period when the preliminary injunction was in effect, however, FinCEN delayed to Jan. 13 the deadline for most businesses to file their initial beneficial ownership information. Businesses created or registered on or after Dec. 3, 2025, will have an additional 21 days from their deadline to file. Deadlines for companies created or registered on or after Jan. 1, 2025, are unchanged. (Banks are exempt from filing, but many of their business clients are covered.)
The lawsuit in Texas was filed by the National Federation of Independent Business and several of its members. The plaintiffs argued that the CTA exceeded Congress’ authority to regulate interstate commerce, that it violates the First Amendment by compelling speech and infringing freedom of association and that it violates the Fourth Amendment by forcing the disclosure of private information.