Proposed ECCTA Implementation 2024-2026

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. Timelines are dependent on relevant systems upgrades at CH and on Parliamentary time, as considerable secondary legislation is required and is subject to change. These dates are therefore indicative rather than definitive. However, it is the clearest indication to date as to the timings of outstanding measures under the ECCTA. These include:

New Identity Verification Requirements

New mandatory identification requirements are being introduced for all new and existing directors, PSCs and those delivering documents to CH on behalf of entities. 

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

These will be two ways to verify an individual:

• directly through a new system to be provided by CH; 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.

Timetable for Identity Verification
Spring 2025
CH should be able to:

• carry out checks on ACSPs to authorise them to carry out ID verification. ACSPs will be required to be registered in the UK and be subject to the UK’s anti-money laundering regime; and
• allow individuals to voluntarily verify their identity via a new CH portal.

Autumn 2025

CH should be able to:

• make ID verification a compulsory part of new incorporations and new director and PSC appointments; and
• begin the 12-month transition phase to require more than 7 million existing directors and PSCs to verify their identity – ID verification will happen as part of the annual confirmation statement filing.

Spring 2026

CH should be able to:

• make identity verification of the 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.

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.

Other reforms of significance that have been given an approximate implementation date include:
Winter 2024/into 2025:

• expedite the striking off of companies where the registrar has concluded the company was formed for a false basis; 
• 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; and
• imposing fines – CH expects to have implemented the systems to allow it to issue financial penalties for relevant offences.

Spring 2025:

• receive and assess applications from individuals seeking to have residential addresses suppressed from public disclosure in certain circumstances.

Spring 2026:

• require third party agents filing on behalf of companies to be registered as an ACSP; and 
• reject documents delivered by disqualified directors, unless they are delivered by an ACSP for specified filings permitted by law.

End of 2026:

• facilitate greater cross-checking of information and data between CH and other public bodies and private sector bodies.

No date specified yet for implementation of:

• abolition of the requirement for companies to maintain certain statutory registers and move to centralised company registers to be held at CH (except for the register of members); 
• existing companies providing one-off statement of their membership information within their confirmation statement;
• restricting the appointment of corporate directors; and 
• accounts reforms.

CH has not yet set a firm timetable for the implementation of these remaining ECCTA measures. It is expected that implementation activity and transitional periods will continue until 2027. CH has also not stated if the timelines for identity verification of directors and PSCs will simultaneously apply to LLP members and whether businesses should expect CH to increase its fees further before the end of 2026.