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Implementation Timetable Update November 2025

The reforms introduced under the Economic Crime and Corporate Transparency Act 2023 (ECCTA) are being implemented in phases. The first phase of implementation occurred on 4th March 2024. On 16th October 2024, Companies House (CH) published its intended implementation timetable of other key measures (which was updated in March 2025 and updated again in August 2025). Timelines are dependent on relevant systems upgrades at CH and on Parliamentary time, as considerable secondary legislation has been required.

November 2025 has seen the latest wave of significant implementation.

New Identity Verification (IDV) Requirements - in force since 18th November 2025

New mandatory identification requirements have been introduced for all new and existing directors and PSCs. 

These measures are designed to make it harder to appoint fictitious directors or beneficial owners and prevent fraudulent appointments.

These are two ways to verify an individual:

  • directly with CH through GOV.UK One Login; or
  • indirectly through a verification statement issued by an authorised corporate service provider (ACSP) which is an intermediary (such as a law or accountancy firm) registered with a supervisory body for anti-money laundering purposes.

Remaining Outstanding Timetable for Identity Verification

By Spring 2026

CH should be able to:

  • make identity verification of presenters a compulsory part of filing any document. Presenters filing any document at CH will need to have completed identity verification or be registered as an ACSP. Documents filed by disqualified directors will be rejected. This is likely to impact company secretaries whose role often includes delivering documents to CH on behalf of an entity or other individuals. They are expected to need to IDV by Spring 2026.

By End of 2026

CH should be able to:

  • complete the transition period for all individuals on the register requiring ID verification and start compliance activity against those who have failed to verify their identity.

Note that corporate directors and officers of Relevant Legal Entities have not yet been included in the IDV regime and no date has been set for their inclusion.

Other reforms of significance include:

  • expedite the striking off of companies where the registrar has concluded the company was formed for a false basis (since 18th March 2025); 
  • annotate the register in a wider range of circumstances, such as when a company has a director who has been disqualified but has yet to terminate their appointment on the register, or where CH has issued a statutory notice to require more information from a person, but the matter remains unresolved; 
  • imposing fines – CH can issue financial penalties for relevant offences (since October 2024); 
  • receive and assess applications from individuals seeking to have residential addresses suppressed from public disclosure in certain circumstances (since 27th January 2025);
  • require third party agents filing on behalf of companies to be registered as an ACSP (expected Spring 2026); and 
  • reject documents delivered by disqualified directors, unless they are delivered by an ACSP for specified filings permitted by law (expected Spring 2026); 
  • facilitate greater cross-checking of information and data between CH and other public bodies and private sector bodies;
  • abolition of the requirement for companies to maintain statutory registers and move to filing information on the centralised register at CH (except for the register of members, which must be maintained as an internal company register at a company's registered office address or single alternative inspection location) (since 18th November 2025); 
  • existing companies providing one-off statement of their membership information within their confirmation statement;
  • restricting the appointment of corporate directors; and 
  • accounts reforms (expected from 1st April 2027).

 

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