HVACR contractors: Federal reporting requirements that impact your business are back in effect. A federal judge has lifted a previously issued nationwide block on the Corporate Transparency Act’s (CTA) reporting requirements, mandating millions of U.S. businesses to report their beneficial ownership information (BOI) to the Treasury Department’s Financial Crimes Enforcement Network (FinCEN). The law, originally passed in 2021 as part of an anti-money laundering initiative, aims to crack down on anonymous shell companies used in financial crimes. However, it has faced legal challenges from businesses arguing that its disclosure requirements are overly burdensome and exceed Congress’s constitutional authority.
Why this matters to you: If your HVACR business is structured as an LLC, corporation, or similar entity, you must now comply with these reporting requirements. Failure to report could result in penalties affecting your business.
On February 17, Judge Jeremy D. Kernodle of the U.S. District Court for the Eastern District of Texas stayed his previous order blocking the CTA’s enforcement, allowing the Treasury Department to implement the law. This decision came after the Biden Administration urged the court to align with the Supreme Court’s recent ruling in a similar case, and after President Trump directed the Secretary of the Treasury to “evaluate beneficial ownership thresholds to ensure sanctions deny Iran all possible illicit revenue” as part of a national security executive order issued on February 4.
FinCEN had already begun accepting voluntary BOI filings after earlier court rulings halted enforcement, but this latest decision means businesses will now have to comply with the reporting requirements. On February 18, FinCEN announced an extension of the BOI reporting deadline to March 21, 2025.
With legal challenges ongoing, Congress is considering delaying the CTA’s reporting deadline. On February 10, the U.S. House of Representatives voted 408-0 to postpone the compliance deadline to January 1, 2026. The measure is now awaiting action in the U.S. Senate. As legal and legislative battles continue, ACCA will monitor developments and provide updates on how the CTA’s implementation may impact HVACR contractors and small businesses nationwide.
Stay tuned for further guidance as the situation evolves.
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