On December 3, 2024, in a lawsuit brought by NFIB and several small businesses, a Texas court blocked the CTA, including the BOI rule, declaring it was likely unconstitutional. 

However, on December 23, 2024, the U.S. Court of Appeals for the Fifth Circuit blocked that injunction, which allowed the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) to enforce the CTA and its BOI reporting requirements. 

This decision was reversed on December 26, 2024, when the U.S. Court of Appeals for the Fifth Circuit once again indefinitely paused the CTA and its BOI reporting requirements.  

Not yet. The Department of Justice has appealed the decision, and this case could go all the way to the Supreme Court. Additionally, the back-and-forth court decisions underscore the need for Congress to repeal the CTA and provide long-term certainty for small businesses. 

The current nationwide injunction puts the rule on hold. The government cannot enforce BOI reporting requirements against any individual or business in any state.  

For now, small businesses that have yet to file the form can hold off—but it shouldn’t be ignored entirely as this case is ongoing.   

If you have already filed with FinCEN there is nothing you need to do. 

Personal Information

• Name
• Birthdate
• Address
• Image of an acceptable government-issued ID showing the ID number and the individual’s picture.

Business Information

• Business name
• Address
• Jurisdiction
• Taxpayer ID number

Impacted small businesses failing to file and maintain accurate personal information face steeply escalating criminal and civil penalties.

• Initial information for each beneficial owner must be filed by December 31, 2024.
• Personal information changes must be updated within 30 days.

Businesses should only file through FinCEN directly.

Avoid scams:

• There is no filing fee.
• There is no “Form 4022.” It does not exist in the U.S. tax system.
• There is no “Business Regulations Department.”