It is just under a year since the Economic Crime and Corporate Transparency Act 2023 (ECCTA) became law and created the framework for radical changes to the role of Companies House. Now Companies House has published a high-level indicative timetable of its full implementation strategy, including in relation to identity verification for directors and others.

Background

An overarching purpose of Part 1 of ECCTA is to change the role of Companies House from that of a largely passive recipient of information to a more active gatekeeper over company creation and the custodian of more reliable data.

Since 4 March 2024, Companies House has had enhanced powers to query information and require inconsistencies to be resolved, reject documents and remove inaccurate information from the register or annotate it. It has also had new obligations and powers in relation to analysing and sharing data with law enforcement agencies and other government departments.

However, for most companies (and LLPs) the direct changes have, to date, been relatively minimal. Many key aspects remain to be implemented, the highest profile being the new requirement for identity verification for directors and others.¹

The indicative timetable

The broad picture is that implementation activity and transitional periods in respect of Part 1 of ECCTA will continue until 2027. Within that, Companies House is working towards certain key dates.² However, these are dependent not just on the relevant systems upgrades at Companies House but also on Parliamentary time, as considerable secondary legislation is still necessary. The dates are therefore indicative rather than definitive. They include:

By spring 2025

• The process for individuals who wish to have their residential addresses suppressed from public disclosure in certain circumstances should be available.

By autumn 2025

• Identity verification is likely to be a compulsory part of incorporation and new appointments for new directors and people with significant control (PSCs).
• A 12-month transition phase, which will require more than 7 million existing directors and PSCs to verify their identity, should begin. The identity verification will take place as part of the annual confirmation statement filing.

By way of reminder, identity verification will, generally, be a one-off requirement. There will be two options: direct verification via Companies House or an indirect route through an Authorised Corporate Service Provider (ACSP). This is a person or organisation that is regulated for the purposes of the UK's anti-money laundering regime (e.g. company formation agents, solicitors, accountants) and has applied to become an ACSP.

By spring 2026

• Restrictions on who can file documents at Companies House are likely to be in place. For third-party agents filing for companies etc., this will include a requirement that they must be registered as an ACSP. Where an ACSP is not involved, only certain categories of individual (e.g. employees) will be eligible to present documents and those individuals will be subject to identity verification.

By end 2026

• End of the identity verification transition period.

Limited partnerships

The ECCTA makes various wide-ranging changes to UK limited partnership law to modernise the regulatory regime for this type of partnership and tackle abuse. These include a new requirement for UK limited partnerships to maintain a registered address in the UK and enhanced Companies House disclosure requirements.³

The indicative timetable does not consider these changes in any detail but notes that the reforms affecting limited partnerships will not take place before spring 2026.

Other changes

Many of the remaining changes which will be made by Part 1 of the ECCTA are either not mentioned in the indicative timetable or are mentioned without a specific timeline beyond the general reference to completion of implementation in 2027. These include the changes which relate to companies' statutory registers, corporate directors and the filing of accounts.

1. For an overview of the changes which remain to be implemented, see https://www.dentons.com/en/insights/articles/2024/march/8/first-reforms-to-uk-companies-house-go-live ↩
2. https://www.gov.uk/government/publications/economic-crime-and-corporate-transparency-act-outline-transition-plan-for-companies-house/economic-crime-and-corporate-transparency-act-outline-transition-plan-for-companies-house#summary-of-changes ↩
3. For more detail, see https://www.dentons.com/en/insights/articles/2022/december/16/upcoming-reform-of-the-uk-limited-partnership-regime ↩