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What further changes can be expected following ECCTA 2023 implementation?
The Economic Crime and Corporate Transparency Act 2023 (the Act) received royal assent in October 2023 and promised a raft of new provisions designed to combat economic crime and provide the public, investors, and government agencies with reliable information about registered entities.
As the Act is implemented, Companies House is moving away from a more passive role as the registrar of companies, towards an active regulator with powers to test and police the reliability of information presented to it. Several key changes have been and are being made to the reporting and filing requirements for companies and directors.
We have already seen the implementation of the requirement to have a "suitable" registered office address, and to provide a registered email address, as well as the introduction of additional powers for the regulator to actively manage and annotate the register.
Below we explore the further key changes coming into force in the next few weeks and what they may mean for your organisation.
Identity verification
One of the most significant changes of the Act will require all directors to verify their identities. New directors will be required to comply before appointment, starting immediately from 18 November 2025. PSCs will have 14 days from appointment to verify their identity. Directors in post before 18 November 2025 have until their company's next confirmation statement date to ensure their ID has been verified, so the deadline will vary from company to company. Directors will not be permitted to act until they have verified their identity, and a failure to comply may result in criminal sanctions.
We recommend that all existing company directors and PSCs start taking steps now to verify their identity with Companies House. There is no need to wait until the deadline is looming. There is a new 'Verify your identity for Companies House' service which can be used for this purpose, which will produce a unique 'personal code', which can be used to connect a verified director to their Companies House records. Alternatively, directors can seek the services of an 'Authorised Corporate Services Provider' (ACSP), who may be offer an ID verification service.
Those who may be considering taking up office as a director in the near future should be informed of the requirements now, so as to smooth the transition to this new regime.
Making filings at Companies House
From 13 October 2025, the individuals eligible to make filings on behalf of a company is to be restricted. Once implemented, only the following will be capable of making filings with Companies House:
- ACSPs (most likely accountants, legal advisors, and company formation agents); and
- Identity-verified employees or directors (or a company secretary) of the company.
Though authorised agents already have a duty to carry out due diligence on their clients, the rules in relation to ACSPs build on this regime. Companies House will expect the same robust approach to company verification whether filings are made directly by those at the company, or indirectly through ACSPs.
This change has the potential to be disruptive, particularly for companies which need to make filings more regularly. Companies should therefore review their internal administrative procedures or consider seeking the assistance of an ACSP where necessary.
Removal of requirement to keep statutory registers
Whilst companies are currently required to keep a number of statutory registers, they will no longer be required by law to keep their own:
- Register of directors;
- Register of directors' residential addresses;
- Register of secretaries; and
- PSC register.
The information above will still need to be recorded and updated at Companies House as it is now. Some companies may find it useful, or choose for good record-keeping purposes, to retain their own registers in any event. It is imperative, however, that the Companies House register is kept up to date as it will function as the sole statutory register for such information.
Companies will still be required to maintain a register of members (or shareholders) at their registered office address, or a single alternative inspection location (SAIL).
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
