Following several legal challenges since its execution, the reporting obligations provided for by the US Corporate Transparency Act have been reinstated.  

On 18 February 2025, the Financial Crimes Enforcement Network (FinCEN) issued an alert that the beneficial ownership information (BOI) reporting is once again mandatory. The new filing deadline is 21 March 2025.  

While a bill has been filed in the Congress to propose a possible postponement of the deadline to 01 January 2026, the current one remains.  

Related read: The CTA’s on-again-off-again history 

The next steps 

With less than a month before the deadline, reporting companies must act swiftly to ensure compliance and avoid fines and legal penalties. The next steps to take:  

1. Identify Beneficial Owners: Determine which individuals own or control at least 25% of the company. Note that exemptions may apply. 
2. Gather Required Information for each Beneficial Owner, including their name, date of birth, residential address, and a valid identification number. 
3. Provide the gathered information for reporting by the new deadline. 
4. Ensure that the company’s internal records are accurate and up to date. If there are any changes, an updated report must be filed within 30 days of the change. 

Bolder Group is closely monitoring this development and can help you with the process. Our representatives are available to answer any questions you may have about the CTA and how this affects your US business.  

Please contact Alaiana Monteiro.

Bolder Group does not provide financial, tax or legal advice and the information contained herein is meant for general information purposes only. We strongly recommend that before acting on any of the information contained herein, readers should consult with their professional advisers. The Bolder Group accepts no liability for any errors or omissions in the information, or the consequences resulting from any action taken by a reader based on the information provided herein.

Bolder Group refers to the global network of independent subsidiaries of Bolder Group Holding BV. Bolder Group Holding BV provides no client services. Such services are provided solely by the independent companies within the Bolder Group which are each legally distinct and separate entities and have no authority (actual, apparent, implied or otherwise) to obligate or bind Bolder Group Holding BV in any manner whatsoever. The operations of the Bolder Group are conducted independently and have no affiliation with third party financial, tax or legal advisory firms or corporations.