The Economic Crime and Corporate Transparency Act (ECCTA) has been a key piece of legislation aimed at enhancing corporate accountability and addressing economic crime, and is set to undergo further changes to further increase transparency and accountability within corporate structures.
1. Identity verification for filings
All filings with Companies House will require identity verification of new and existing directors, persons with significant control (PSCs), relevant officers of a registrable relevant legal entity (RLE) and members of limited liability partnerships. Verification can be completed via direct verification with Companies House (this is free and can be done online through GOV.UK One Login or in person at the Post Office) or indirect verification carried out through an Authorised Corporate Service Provider (ACSP). It is expected that most UK based individuals should be able to use the free Companies House verification service, but this service may not be suitable for all non-UK based directors and PSCs.
2. Role of ACSPs
If an individual is unable to verify directly with Companies House, they will need to use an ACSP (with a fee likely to be charged). The ACSP regime is designed for intermediaries such as accountants and legal advisers who are already undertaking anti-money laundering (AML) checks to become ACSPs. Prior to making any filing as an ACSP, entities must register with the Companies House Registrar (there is a fee of £55) and confirm their own status as supervised by an AML supervisory body and confirm that they have conducted all necessary identification checks on their clients.
3. Severe consequences for failure to comply
An individual who is under a requirement to verify their identity with the Registrar, and fails to comply with it, could be subject to, among other things, criminal proceedings, civil penalties issued by the Registrar of Companies, being unable to file statutory filings and applications to register new companies being rejected.
4. Companies House implementation timeline
From 8 April 2025 Companies House allows individuals to voluntarily verify their identity.
By summer 2025 Companies House is expected to allow access on request to certain trust information on the Register of Overseas Entities; and
By autumn 2025 Companies House is expected to make identity verification a compulsory part of incorporation and new appointments for new directors and PSCs and the 12 month transition phase is expected to commence requiring more than 7 million existing directors and PSCs to verify their identity (the identity verification will happen as part of the annual confirmation statement filing).
By spring 2026 Companies House is expected to:
- make identity verification of the presenters a compulsory part of filing any document;
- require third party agents filing on behalf of companies to be registered as an ACSP; and
- reject documents delivered by disqualified directors as they will be prohibited from doing so, unless they are delivered by an ACSP for specified filings permitted by law.
By the end of 2026 Companies House is expected to:
- require all limited partnerships to submit more information, providing greater transparency for users of the register; and
- complete the transition period for all individuals on the register requiring identity verification, and start compliance activity against those who have failed to verify their identity.
5. Next Steps
The voluntary verification process has been available since 8 April 2025 and directors and PSCs should strongly consider verifying their IDs at Company House now so they are not risking failure to comply when it becomes mandatory by their company's next confirmation statement.
