Updates to templates following ECCTA delays and new ECCTA Roadmap added
The original timetable for implementation of the changes to filing at Companies House under the ECCTA stated that the identity verification (IDV) requirements for those filing on behalf of companies would come into force in Spring 2026. This second phase of the IDV regime will require all those filing at Companies House, including company secretaries, to identity verify. Companies House has recently announced that this change will now not take place before November 2026. Until then, there will be no change to the filing procedures at Companies House and filing can continue to be done in the usual way. The requirement for third parties filing on behalf of companies to be registered as authorised corporate service providers (ACSPs) will be brought into force at the same time.
The reason for the delay is to allow Companies House to prioritise the completion of the mandatory IDV rollout for directors and individual PSCs.
IDV requirements for corporate directors, corporate members of LLPs and corporate PSCs will be introduced at a later date.
It has also been announced that the new ECCTA regime for filing annual accounts will now not come into force on 1 April 2027. Companies House had previously indicated that mandatory software filing of accounts and other changes, including removal of the option for small companies to file abridged accounts, would take effect on 1 April 2027. Companies will be given at least 21 months' notice to prepare for any changes.
In consideration of these changes to the implementation timetable the following templates have been updated:
- Summary of the Identity Verification Regime
- Checklist of Headline Points for the ECCTA
- Note to Directors - Summary of key issues under the ECCTA
- Guidance Note: Company Secretary in a Private Company
- Board Minutes to Approve Company Secretary filing on Company's Behalf at Companies House
- Consent to Act (Confirmation from Company Secretary)
- Request Letter of Authority for Company Secretary to file on Director/PSC's Behalf at Companies House
- Confirmation from Director/PSC for Company Secretary to file on their Behalf at Companies House
In addition, a Roadmap has been added for the ECCTA to provide a clear, chronological guide to the rollout of the legislation (those provisions already implemented and those due to take effect).
These templates will be useful for company directors, shareholders, company secretaries and administrators navigating these key reforms.
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.