Economic Crime & Corporate Transparency Act 2023 – Changes to Register of Members

The Economic Crime & Corporate Transparency Act 2023 (ECCTA) is making changes to the register of members. Most significantly this includes (1) removing the option to keep this register on the central register at Companies House, therefore the register of members will have to be maintained as an internal local register; (2) new “required information”, including a new definition of a member’s name whereby a forename and surname must be included with no initials or abbreviations allowed; (3) and greater powers for a company to obtain the “required information” from members.

In consideration of these changes:

• our guidance notes outlining the law as it relates to the register of members has been updated; 
• the template register of members (basic version) has been updated. It is expected that all the changes that will affect the register of members will be implemented during 2024. For newly incorporated companies or companies making changes to their register of members, it is recommended to transition to this version now as this will likely become the default version by the end of 2024. Our existing register of members (basic version) will remain live until all the ECCTA changes have been implemented; and
• the template register of members (long form) has been updated to incorporate the ECCTA changes. This register is more detailed and given the need to protect member information, this longer form should only be used as an alternative internal company register separate from the statutory register.

Our guidance note also includes a discussion of responsibility for maintaining the register, the contents of the register, indexing the register, single member companies, data protection and the register of members, the inspection regime, the obligations on companies to comply with requests for inspection as well as all the changes being implemented under the ECCTA.