Economic Crime & Corporate Transparency Act 2023 – Changes to Filing on Behalf of Someone else at Companies House, Implications for a Company Secretary

Filing at Companies House – from Spring 2026 a company secretary will need to be identity verified to file 

The Economic Crime & Corporate Transparency Act (ECCTA) has significantly reformed the role of Companies House (CH). The legislative changes that the ECCTA has introduced are underpinned by statutory objectives that provide a framework for how CH operates and exercises its new powers. Several of these objectives relate to the filing and delivery of documents to CH.

An individual must be identity verified (IDV) to file on their own behalf at Companies House and from Spring 2026, this will include that an individual filing on behalf of an entity or another individual, must also IDV. For many SME companies this will impact the company secretary, who may be an employee of a company and whose role is likely to include making all appropriate filings for the company, its officers and persons of significant control at CH. With the abolition of certain statutory registers, there will also be more to file with CH, all of which must be filed promptly (usually within 14 days).

It is therefore strongly recommended that an individual delivering a document to CH on behalf of another person or entity is given specific authority by that company or individual concerned.

The templates below assume that the company secretary is either an officer or an employee of a SME private company. Note that a company secretary who is neither an officer nor an employee of a company, i.e. a third-party provider, who will be carrying out IDV on behalf of clients, will first need to register as an Authorised Corporate Service Provider (ACSP) with CH. In the future (expected to be by Spring 2026), businesses will also need to register as an ACSP in order to be able to file on behalf of third-party clients.

New templates

Considering this, the following new templates have been added:

• Board Minutes to be used by a company to authorise the company secretary to file on the company’s behalf.
• Letter from a company to its directors and PSCs explaining the new rules and requesting that the individual director or PSC authorises the company secretary to file on their behalf.
• Confirmation from an individual director or PSC confirming the individual authorises the company secretary to file on their behalf at CH.
• Letter confirming that a company secretary (other than on incorporation) has consented to act as such in accordance with section 279G(3)(b) of the Companies Act 2006, enabling the company to make the necessary declaration to Companies House on Form AP03 or AP04.

Updated templates

In addition, the following templates have been updated to reflect the changes the ECCTA is introducing that will impact the company secretary: 

• Guidance notes: The Company Secretary in a Private Company.
• Board Minutes – Appointment of a Company Secretary.