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The sixth commencement order for the Economic Crime and Corporate Transparency Act 2023 (ECCTA) has been made which brings into force from 18 November 2025 the mandatory identity verification (IDV) requirements for directors and individual persons with significant control (PSCs), and the abolition of the requirement for companies to maintain certain local registers. The Economic Crime and Corporate Transparency Act 2023 (Commencement No. 6 and Transitional Provisions) Regulations 2025 also set out the transitional arrangements which apply in relation to the commencement of these provisions of the ECCTA.
Mandatory IDV requirements
The mandatory IDV requirements introduced by the ECCTA apply to all new and existing directors (and equivalents for other entities), PSCs and those filing information with Companies House. The requirements are being introduced in a phased manner, with directors and individual PSCs forming the first implementation wave. Individual members of limited liability partnerships (LLPs) and individual PSCs of LLPs are also in this first wave, under changes introduced to the regime governing LLPs by The Limited Liability Partnerships (Application and Modification of Company Law) Regulations 2025. For overseas companies with a UK establishment, any individual who acts as a director of the company in relation to the UK establishment must also comply with the IDV requirements from 18 November 2025. The IDV requirements for other groups, including those filing information with Companies House, limited partnerships, officers of corporate PSCs and corporate members of LLPs will be brought into force in due course.
For existing directors, individual PSCs and individual LLP members, there are transitional arrangements commencing on 18 November 2025. The deadlines for confirming verified status to Companies House are:
- For existing directors: when the company's first annual confirmation statement after 18 November 2025 is filed;
- For individual PSCs who are also directors: within 14 days of the company's first confirmation statement due date falling after 18 November 2025;
- For individual PSCs who are not also directors: within 14 days of the first day of their month of birth falling after 1 December 2025;
- For existing individual members of an LLP: when the LLP's first annual confirmation statement after 18 November 2025 is filed;
- For existing individual PSCs of an LLP who are also members of the LLP: within 14 days of the LLP's first confirmation statement due date falling after 18 November 2025;
- For existing individual PSCs of an LLP who are not also members of the LLP: within 14 days of the first day of their month of birth after 1 December 2025; and
- For directors of an overseas company with a UK establishment: by the first anniversary of the date the overseas company registered the UK establishment falling after 18 November 2025.
Regulations have also been made in relation to the annotation of the register for verification status. The Companies and Limited Liability Partnerships (Annotations, Application and Modification of Company Law and Consequential Amendments) Regulations 2025 come into force at the same time as the IDV requirements set out above and once Companies House has received notice under the Registrar (Identification Verification and Authorised Corporate Service Providers) Regulations 2025 that the individual's identity has been verified, it must note this in the register.
For more background on the new IDV regime, please see our snapshot here.
Abolition of certain statutory local company registers
From 18 November 2025, companies will not be required to create or maintain a:
- register of directors;
- register of directors' residential addresses;
- register of secretaries; or
- PSC register.
The information which would otherwise be recorded in these registers still needs to be provided to Companies House.
Companies House had announced that the removal of the option for private companies to elect to use the central register held by Companies House to record shareholder information (in lieu of entering shareholder information on their own, locally-held register) would take effect from 18 November 2025. This would mean that from that date, any private companies which had previously made such an election would need to create and maintain their own shareholder register. This change has not been included in the sixth commencement order and so its commencement date has not yet been confirmed.
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.
