The Economic Crime and Corporate Transparency Act 2023 (ECCTA) HAS introduced new laws to tackle economic crime and deliver a more reliable companies register to underpin business activity.
Central to these changes are new identity verification (IDV) requirements and updates to the way companies maintain their internal registers, which will be introduced in phases (see our earlier article Companies House ID Verification: What’s Changing and How to Prepare).
Our Corporate Lawyers explain what these reforms mean for your business and how to prepare.
Who will need to verify their identity?
Companies House have published guidance confirming that the following individuals will be required to verify their identity:
- Company directors. This includes directors of companies limited by guarantee, unlimited companies, unregistered companies subject to the provisions of the Unregistered Company Regulations and directors of overseas companies operating a branch in the UK and who have registered that UK establishment with Companies House
- Relevant officers of RLEs of a company or an LLP
- LLP members
- Nominated directors of corporate general partners of limited partnerships
- Individuals who are ACSPs
- Those persons delivering documents to Companies House
How can IDV be completed?
- IDV can be completed online with Companies House using GOV.UK One Login, in person at a Post Office via the One Login Face to Face service or through an Authorised Corporate Service Provider (ACSP).
- Once a person has completed IDV, they are provided with a unique code by Companies House. This personal code proves that their identity is verified. This code is required for directors, LLP members and PSCs to connect their verified identity to Companies House records.
- If an individual does not have any of the identity documents required by Companies House and/or does not have a UK home address in the case of the One Login Face to Face service, they will be unable to verify their identity directly with Companies House and will instead be required to request an ACSP to verify their identity.
Timing for the implementation of IDV
Since 8 April 2025, individuals have been able to voluntarily verify their identity using GOV.UK One Login or via an ACSP.
Companies House has since confirmed that directors, PSCs, and LLP members will be required to verify their identity from 18 November 2025, with a 12-month transitional period. The triggers for compulsory IDV are the following:
- New directors will be required to provide their Companies House personal code when registering a new company or being appointed to an existing company.
- New PSCs will be required to provide their personal code within 14 days of being added to the Companies House register.
- Existing directors will be required to provide their Companies House personal code as part of their company's next confirmation statement filing. Individuals with more than one directorship will be required to do this for each company of which they are a director.
- Existing PSCs, who are also directors of the same company, must provide their personal code as a director as part of the relevant company's confirmation statement filing and must provide their personal code as a PSC within 14 days of the relevant company's confirmation statement date (via a service which will be made available when the requirement comes into force).
- Existing PSCs, who aren't also directors of the same company, must provide their personal code within the first 14 days of their birth month.
It is not yet clear when IDV will be introduced for officers of RLEs, corporate directors of companies and corporate members of LLPs.
However, Companies House has previously stated that it anticipates the following:
Spring 2026
IDV will be required for presenters filing any document and corporate general partners of limited partnerships. Third-party agents filing on behalf of a company will be required to be registered as an ACSP.
By the end of 2026
The transition period for requiring IDV will be completed, and compliance activity will be started against those who have failed to complete IDV where required to do so. Implementation of IDV for limited partnerships will also start to come into force.
Changes to company registers
Alongside the implementation of IDV requirements, the reforms introduced by section 51 of ECCTA 2023 will take effect from 18 November 2025.
These reforms remove the requirement for companies to maintain their own local registers containing information on their directors, directors' residential addresses, secretaries and people with significant control.
Instead of keeping a local register, companies will be subject to enhanced reporting obligations requiring the information that would have been kept in these registers to be provided to Companies House directly, where it will be held centrally.
Additionally, companies will no longer need to provide directors' business occupations when registering their appointments with Companies House. The option to hold officer information on the central register will also be removed.
Companies House has also indicated that companies will no longer be able to elect to hold information about their officers on the central register maintained by Companies House.
By law, however, companies will still have to hold a register of shareholders either at the company’s registered office address, or single alternative inspection location (SAIL).
Those that previously held their register of members at Companies House will now need to create and maintain their own register, hold it at their registered office or SAIL address, include a statement about their previous use of the central register and make it available for public viewing.
Contact Our Corporate Team
If you need advice navigating the new ECCTA requirements, our Corporate Lawyers are here to help. Contact us today for clear, practical guidance.
0161 941 4000
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Alexia Dirgau
Solicitor Apprentice
Alexia joined Myerson in September 2022 as a solicitor apprentice after finishing her studies at Loreto Sixth Form College in Manchester.
Alexia has completed her first seat in our business administration department where her main responsibilities involved the general support of fee earners and PAs, followed by her second seat in marketing and a third as a Legal PA.
Alexia is currently undertaking one of her legal seats in our Dispute Resolution department.
Alexia will continue moving around the firm through the different departments as she progresses through her 6-year apprenticeship, whilst also studying Law part-time LLB at BPP University.
About Alexia Dirgau