Records

The Companies House Overhaul and What It Means

The Desk, 7 min read

The Economic Crime and Corporate Transparency Act 2023 (often shortened to ECCTA) is the largest legislative change to UK company law in a generation. It came into force in stages from March 2024 onwards, and its provisions continue to roll out into 2026. The change is incremental in any single respect; the cumulative effect on what is presently knowable about a UK private company is substantial.

Three changes matter most to a reader of registers.

First, identity verification. Every individual filing at Companies House from 2024 onwards is required to verify their identity to a designated verification standard. The verification is held against the individual's record at Companies House and is reused for subsequent filings. For a private client with a UK directorship, this means an identity record now exists at Companies House that is materially harder to obfuscate than before.

Second, the role of the company-formation agent has changed. Agents who form UK companies must themselves be supervised by an HMRC-recognised AML supervisory body. The lists of supervised agents are public. A company formed through a non-supervised agent or through an offshore-introducer chain that ECCTA does not recognise is now harder to incorporate; for clients who used to form UK structures through such routes, the route has effectively closed.

Third, the discretion of the Registrar has expanded. The Registrar may now reject filings that are inconsistent with information already on the register or that fail integrity checks. The practical effect is that statements of capital, registered offices, and director appointments are increasingly cross-checked rather than simply accepted. Inconsistencies that previously went unnoticed are now flagged at filing.

For an audit, the consequence is that the UK record of a private client's corporate footprint is now meaningfully more complete and meaningfully more consistent than it was three years ago. Where the audit reads Companies House, what the audit reads is what a counterparty's compliance team would also read. The discrepancies that ECCTA is designed to surface are findable; the audit identifies them.

There is a wider lesson here that applies beyond the UK. The trend in the major financial-centre jurisdictions is for registers to become more integrated, more cross-checked, and harder to leave incomplete. Singapore's ACRA, Ireland's CRO, the EU's UBO regime, and the Cayman beneficial-ownership register have all moved in this direction in the past three years. The picture available to a counterparty about a private client is more complete today than it was in 2023, and it will be more complete still in 2027.

What this calls for in a private client is not panic. It is hygiene. The audit reads the picture as it currently stands; corrective work follows from what the reading surfaces. Material inconsistencies, where they exist, can usually be corrected. The work is in identifying them.

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