Companies House reform – major changes in the UK
Barbara Hughes & Vicky Brown
by Barbara Hughes and Vicky Brown
In the United Kingdom, Companies House is implementing significant changes under the Economic Crime and Corporate Transparency Act 2023 (ECCTA) – particularly around identity verification and the registration of third-party agents as Authorised Corporate Service Providers. This is the biggest shake up of UK Company Law since 2016, which will be implemented from Spring 2025 to Autumn 2026.
Identity verification
Non-resident officers and people with significant control (PSCs)
Under UK law, non-UK resident individuals:
Are permitted to act as company directors, LLP members, or equivalent; and
By virtue of their ownership of shares in a UK company (or interest in a non-UK corporate shareholder, or a significant interest in an LLP) may be registered at Companies House as a person with significant control (PSC).
Any non-resident directors, members, or PSCs will be impacted by these legislative changes and will need, in due course, to verify their identity.
The process
Whilst details are still emerging, we understand that:
Verification will be via an online portal using facial recognition technology.
Once an individual’s identity is verified, a code (personal to that individual) will be issued to the individual’s email.
This code will need to be shared with anyone who files documents at Companies House on the individual’s behalf.
Companies House have now issued the following preliminary timetable:
Spring 2025: The portal will open and individuals will have the option to voluntarily verify their identity.
Autumn 2025: Identity verification will be compulsory for all individuals when incorporating a new UK company, appointing a new director or member, or registering a new PSC.
From Autumn 2025: A 12-month transitionary period will begin whereby personal codes for all directors, LLP members, and PSCs (including representatives of corporate directors or PSCs) will need to be included in annual confirmation statements (CS01 forms).
By the end of 2026: All individuals will need to have completed identity verification and action will be taken in respect of any non-compliance.
All individuals acting as UK directors or LLP members, or registered as PSCs, are encouraged to begin the verification process early and obtain their personal codes.
Third-party agent registration
All third-party agents (such as solicitors, accountancy firms, or formation agents) who file documents with Companies House on behalf of their UK clients will be required to register their business as an Authorised Corporate Service Provider (ACSP) and verify their identity.
In order to register as an ACSP, the business must be supervised by one of the UK’s Anti-Money Laundering (AML) supervisory bodies.
The registration process will open in Spring 2025. By Spring 2026, documents will no longer be able to be filed by an agent who is not registered as an ACSP.
Any non-UK based solicitors or accountancy firms (who are not supervised by a UK AML supervisory body) will no longer be able to file at Companies House on behalf of their UK clients, and alternative arrangement will need to be made.
Further information on Companies House reforms under the ECCTA is available here:
Changes to UK company law - Changes to UK company law. You can register to receive email updates here.
Vicky Brown is an Associate Director in Gerald Edelman's secretarial department. Her role is very client-focused and varied. Vicky enjoys being regularly involved in all kinds of tasks from incorporations to striking off applications – and almost everything in between. Contact Vicky.
Barbara Hughes' focus is providing clients with a comprehensive service covering all aspects of company secretarial and statutory compliance work. She works with clients on new company formations, re-registrations and dissolutions, liaising with directors, shares re-organisations, Companies House filings and all associated statutory compliance matters. Contact Barbara.
XLNC member firm Gerald EdelmanLondon, England, UKT: +44 20 7299 1424
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