Companies House has published an outline transition plan which sets out the proposed timeline for implementation of key parts of the Economic Crime and Corporate Transparency Act 2023 ("ECCTA").
As we wrote about in our Insight article in February, a raft of ECCTA provisions affecting companies came into force on 4th March 2024, including the requirement to have a registered email address and the lawful purposes confirmation needed on incorporation and annually. Since then, we have been waiting for a steer from Companies House on when we could expect the bringing into force of ID verification and other provisions of ECCTA aimed at stamping out the use of companies for economic crime purposes, as covered in this Insight article.
ID verification of directors: autumn 2025 onwards
Under ECCTA, all directors will need to have their identity verified, either using the Companies House system or via an Authorised Corporate Service Provider ("ACSP"). According to the transition plan, by autumn 2025, ID verification will be mandatory on new incorporations and on appointments of new directors.
This will also be the start of a 12-month transitional phase during which all existing directors must verify their identity as part of the annual confirmation statement process. By autumn 2026, all directors must have had their ID verified.
ID verification of Persons with Significant Control ("PSCs"): autumn 2025 onwards
ECCTA also imposes an ID verification requirement on individuals who are PSCs of UK companies and on managing officers of relevant legal entities ("RLEs") which are PSCs of UK companies, such as another UK company. ID verification for PSCs will also become compulsory on new incorporations by autumn 2025.
The same transitional period will apply to PSCs, with the need to ID verify individual PSCs or managing officers of RLEs by autumn 2026.
It is worth noting that companies are not responsible for verifying the identity of their PSCs – it is the PSC themself which must comply with the ID verification requirement.
Voluntary IDV for directors and PSCs
Companies House is planning for individuals to be able to voluntarily verify their identity from spring 2025.
How to verify your ID
Companies House has recently announced that the GOV.UK One Loginsystem, currently used to access certain governmental services, will be one way for people to verify their identity. We will be publishing more detailed information on how to verify identity as soon as we can.
ID verification required for filing at Companies House: by spring 2026
As part of the ECCTA measures to ensure the integrity of the Register, anyone filing at Companies House will need to have their ID verified by spring 2026.
Any third party filing on behalf of a company will need to be registered as an ACSP by then.
Limited partnership reforms: by the end of 2026
Companies House is aiming to have the reforms to limited partnership law in place by the end of 2026. This will involve limited partnerships being required to submit more information to Companies House and more transparency around limited partnerships, as a result. For more information on this, please read our Insight article on this.
If you would like more information on how the ECCTA will impact your business, please contact the authors or your usual Brodies contact.
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