Many of the key provisions of the Economic Crime and Corporate Transparency Act 2023 (ECCTA), including ID verification and the requirement for companies to have a registered email address and an appropriate registered office, have been brought into force over the past two years. However, Companies House has recently announced that there will be delays to implementation of some of the remaining provisions of ECCTA which affect companies.
Changes to filing at Companies House
The original timetable for implementation of the changes to filing at Companies House under ECCTA stated that they would come into force in Spring 2026. Companies House has recently announced that this change will now not take place before November 2026. Until then, there will be no change to the filing procedures at CH and filing can continue to be done in the usual way, whether that is done by the company itself or through their lawyers.
Once the new regime under ECCTA comes into effect, filing at Companies House will only be able to be done either by a person who has had their ID verified or by an Authorised Corporate Service Provider (ACSP).
Indefinite postponement of changes to accounts filing
The new ECCTA regime for filing annual accounts will not now come into force on 1 April 2027. Companies House had previously indicated that mandatory software filing of accounts and other changes, including removal of the option for small companies to file abridged accounts, would take effect on 1 April 2027.
The reforms are apparently still under review and a final decision will be announced shortly. Companies will be given at least 21 months' notice to prepare for any changes.
Corporate director limit
It had been anticipated that this would come into force at some point in 2026 but there is still no confirmed date for its implementation. However, the outline of how the ban will be implemented for corporate directors of UK companies has been confirmed as follows:
- a corporate director of a company must itself have a board constituted entirely of natural persons;
- all the directors of the corporate director will be required to verify their identity in order for the corporate director to be registered at Companies House; and
- only UK corporate entities with legal personality will be capable of acting as a corporate director. The use of overseas companies acting as corporate directors in the UK will be prohibited.
We will continue to monitor implementation of the remaining parts of ECCTA affecting corporates but if you need advice on the impact of ECCTA in the meantime, please contact the authors or a member of our Corporate team.
Contributors
Practice Development Lawyer
Partner
