The BOI reporting requirements by FinCEN remain controversial, with enforcement efforts facing significant legal challenges. The federal government has appealed the court’s December 3rd decision. While the injunction temporarily suspending BOI reporting was lifted briefly, it has since been reinstated.

Below is a quick summary and timeline of the current status of the temporary injunction order:

Dec. 3, 2024 – BOI Reporting Suspended

On December 3, 2024 a federal district court in Texas ruled that the Corporate Transparency Act (CTA) is likely unconstitutional and issued an order (“injunction”) prohibiting the enforcement of the beneficial ownership information (BOI) reporting rule in the CTA’s accompanying regulations. The court chose to apply this injunction nationally, and not just to Texas.

Dec. 23, 2024 – BOI Reporting Reinstated

The Fifth Circuit US Court of Appeals “stayed” this injunction on December 23, 2024 which REINSTATED the BOI reporting requirements. It give authority back to Financial Crimes Enforcement Network (FinCEN)​ to require the BOI Reporting and enforce their deadlines. The original deadline was January 1, 2025, however shortly after the court’s ruling, FinCEN extended the BOI Reporting deadline to January 13, 2025 for most reporting companies.​

Dec. 26, 2024 – BOI Reporting Suspended Again

The New Orleans-based Fifth Circuit US Court of Appeals late Thursday “vacated” the December 23rd “stay”, so the December 3rd “injunction” is back in place.