Pharmacists must now (once again) comply with CTA disclosures

From NCPA.org, National Community Pharmacists Association

Under the Corporate Transparency Act, small businesses (including pharmacies) with 20 or fewer full-time employees that do not otherwise meet an exemption must file a beneficial ownership information report with the U.S. Treasury's Financial Crimes Enforcement Network. Whereas those requirements had been recently suspended, with a Feb. 18, 2025 decision by the U.S. District Court for the Eastern District of Texas, BOI reporting requirements are once again in effect.

Because the Department of the Treasury recognizes that reporting companies may need additional time to comply with their BOI reporting obligations, the deadlines have been extended:

• For most reporting companies, the new deadline to file an initial, updated, and/or corrected BOI report is now March 21. FinCEN will provide an update before then of any deadline changes as reporting companies may need additional time to comply with their BOI reporting obligations once this update is provided.

• Reporting companies that were previously given a reporting deadline later than March 21 must file their initial BOI report by that later deadline. For example, if a company’s reporting deadline is in April 2025 because it qualifies for certain disaster relief extensions, it should follow the April deadline, not the March deadline. 

FinCEN indicated that there are very narrow exceptions to the reporting requirements: Isaac Winkles, reporting companies for which Isaac Winkles is the beneficial owner or applicant, the National Small Business Association, and members of the National Small Business Association as of March 1, 2024 are not currently required to report their beneficial ownership information to FinCEN at this time.  

Reporting companies can report their beneficial ownership information directly to FinCEN, free of charge, using FinCEN’s E-Filing system available at https://boiefiling.fincen.gov. More information is available at fincen.gov/boi. 

NCPA advocated for the CTA's repeal or delay in April 2024, September 2024, December 2024 and January 2025, and will keep members posted on further developments. 

NCPA