As a result of the Fifth Circuit's emergency stay, the January 1, 2025 deadline for the Corporate Transparency Act — which requires over 33 million businesses in the United States to file beneficial ownership information or face penalties of up to $10,000 — has been reinstated.

FinCEN has appealed a recent federal court ruling that temporarily blocked the Corporate Transparency Act (CTA) and its Beneficial Ownership Information Reporting (BOIR) rules. Along with the appeal, FinCEN has requested an emergency stay to reverse the injunction and potentially reinstate the January 1, 2025, compliance deadline. If granted, businesses would need to comply with the reporting requirements, which include disclosing ownership details.

New York has updated its LLC laws to enhance corporate transparency, effective January 1, 2026. These changes require LLCs to disclose beneficial ownership information to the state, mirroring the federal Corporate Transparency Act (CTA) and FinCEN's Beneficial Ownership Information Reporting (BOIR). The CTA, effective January 1, 2024, mandates that most entities report their beneficial owners' details to FinCEN.