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Updated ECCTA transition plan confirms delay to next phase of the Identity Verification rollout

August 2026

Companies House has updated its outline transition plan for the implementation of company law reforms under the Economic Crime and Corporate Transparency Act 2023 (ECCTA). 

Most notably, the introduction of identity verification (IDV) requirements for those filing on behalf of companies at Companies House has been delayed and will now come into effect no earlier than November 2027. Companies House has also stated that it will give at least six months' notice before the new requirements come into effect. The timing for the implementation of these requirements had already been delayed in January 2026 to allow Companies House to complete the first phase of the rollout of mandatory IDV for directors and individual PSCs.

Under the new restrictions, a company or other firm will only be able to file documents at Companies House through an ID verified officer or employee (such as a company secretary) or by using an authorised corporate service provider (ACSP). These new restrictions are designed to minimise fraudulent filings, combat economic crime and enhance the quality of the public register. 

The updated transition plan also anticipates that by no earlier than the end of 2026 the first phase rollout of mandatory IDV will be complete and Companies House will be able to commence steps to ensure compliance by those in-scope individuals who are in default; Companies House will also be able to reject documents delivered by disqualified directors.

Considering this change to the implementation timetable, the following templates have been updated:

  • the ECCTA Roadmap;
  • the ECCTA checklist;
  • Note to Directors - summary of key issues under ECCTA
  • Summary of IDV Regime;
  • Guidance Note: Company Secretary in a Private Company;
  • Consent to Act (Confirmation from Company Secretary);
  • Board Minutes to Approve Company Secretary Filing on Company’s Behalf at Companies House; and
  • Request Letter of Authority for Co Sec to File on Director/PSC’s Behalf at Companies House.

 

The contents of this Newsletter are for reference purposes only and do not constitute legal advice. Independent legal advice should be sought in relation to any specific legal matter.

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