Checklist of Headline Points for Economic Crime Act for Charitable Companies Limited by Guarantee (CCLBGs)

This checklist provides an overview of the headline points that all CCLBGs should be aware of in the Economic Crime and Corporate Transparency Act 2023 (ECCTA). It will help CCLBG trustees (i.e. the directors of the CCLBG), charity secretaries and administrators considering the requirements of this legislation and plan how they will communicate and implement the changes. 

The ECCTA gives Companies House new and enhanced powers to help disrupt economic crime.

It is important that all relevant parties are aware of the existing and upcoming changes and their consequences, particularly the: 

• need for ID verification of directors (the charity trustees), PSCs and relevant third parties; 
• extra powers of Companies House; 
• changes to filings; and 
• the changes to accounts. 

The ECCTA has been progressively been implemented (by secondary legislation) since 2024 and is still being brought into force in stages (Companies House has said that some parts will not start before November 2027), but CCLBGs need to communicate the contents of the ECCTA, to arrange how the ID of directors and PSCs is to be verified, how the full details of members are gathered (abbreviated names will no longer be allowed once the relevant provisions are in force), whether there are known errors or inconsistencies in existing filings that need to be rectified, whether extra resources are needed to manage the changes and whether existing processes/procedures need to be changed.

Many of the measures under the ECCTA are already in force and this checklist reflects up to date information on timing of implementation issued by Companies House. 

The provision of most significance and interest is the identity verification regime. Voluntary ID verification began on 8th April 2025. ID verification is compulsory for directors and people with significant control from 18 November 2025; Companies House has said that verification for people who file documents will follow no earlier than November 2027.

This checklist, whilst not a full list, details the main reforms and the action required to be taken by CCLBGs to meet the requirements of the ECCTA.

Companies House guidance in relation to the identity verification process is available here.

Our guidance note here provides further details about appointment of trustees/directors of a charitable company.

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