U.S. District Court halts enforcement of BOI reporting rules – for now

On Dec. 3 the U.S. District Court for the Eastern District of Texas suspended nationwide the implementation of the Corporate Transparency Act’s (CTA) Beneficial Ownership Information (BOI) reporting requirements. 

The District Court issued an opinion and order in the case of Texas Top Cop Shop, Inc., et al. v. Merrick Garland, Attorney General of the United States (Case No. 4:24-cv-478). The court found that the CTA likely is unconstitutional. 

Please note this is a preliminary injunction, and BOI reporting companies are urged to pay attention to additional updates and proceedings on appeal in this and other cases that could modify or change this order. You can find a copy of the order here. 

The Department of Justice filed a formal notice of appeal to the Fifth Circuit on Dec. 5 to challenge the court’s preliminary injunction. OSCPA has also signed a Dec. 4 letter along with numerous other state CPA societies urging FinCEN and the U.S. Treasury Department to push back the deadline for initial filings by at least one year to no earlier than Jan. 1, 2026.