Register Of Company Secretaries (Individuals) (internal use only)

A private company is not required to have a company secretary (section 270, Companies Act 2006). However, many companies still appoint a company secretary to assist with administrative tasks and to take on some of the directors’ responsibilities.

Who can act as a company secretary?

A company secretary can be a director, but cannot be:

• the company’s auditor; or
• an undischarged bankrupt (unless they have permission from the court).

Even where a company has a company secretary, the directors remain legally responsible for the company.

If a private company has a company secretary, it may be an individual or a corporate secretary (including a firm).

ECCTA changes to the register of secretaries

Under the Economic Crime and Corporate Transparency Act 2023 (ECCTA), the requirement for companies to maintain statutory registers (other than the register of members) is abolished with effect from 18 November 2025. This includes the register of secretaries.

The register at Companies House will become the sole, verified source of this information. The ECCTA also creates stringent requirements for keeping Companies House updated on changes. Appointments, resignations and changes in a secretary’s details must be notified to Companies House within 14 days of the change occurring.

Why keep an internal register of secretaries?

Although companies may dispense with the statutory register of secretaries, many may still choose to maintain an internal record for governance and practical reasons, at least for the time being.

An internal register may be helpful:

• as good housekeeping and governance, to keep an organised internal record of information previously kept in statutory registers; and
• for due diligence when engaging with third parties (particularly investors and entities from abroad), when seeking a loan, or where the company is the target in an acquisition.

What this template is for

This template can be used by companies that wish to continue maintaining an internal register of company secretaries after 18 November 2025. It has been updated to reflect that it is now purely an internal record.

Register Of Company Secretaries (Individuals) (internal use only) is part of Corporate. Just £38.50 + VAT provides unlimited downloads from Corporate for 1 year.