The reforms will materially increase transparency but with an added compliance burden on companies, directors and advisers. Implementation has begun and is phased through 2027, so planning ahead is essential.
What is already in force:
• Stronger Companies House (CH) powers: CH now has a statutory objective to ensure the integrity of the register and prevent misuse. It can query, reject, annotate or remove information; require additional evidence; share data with HMRC, the FCA and others; and impose civil penalties directly.
• Registered office and email: a company’s registered office must be an “appropriate address” (no PO boxes or unmonitored virtual addresses). All companies must maintain a registered email for official CH communications. Non-compliance can lead to a default address and, ultimately, strike-off for repeated offences.
• Confirmation statement changes: at incorporation and annually, companies must confirm they operate for a lawful purpose, provide/update a registered email, and ensure accurate SIC codes. CH is now actively cross-checking filings for inconsistencies (for example, dormant status vs trading accounts).
• Name scrutiny: CH can reject or require changes to misleading or inappropriate company names, including those implying government links or regulated status without authorisation.
Identity verification is the headline change with the most administrative burden on individuals and advisers alike. From 18 November 2025, mandatory identity verification (IV) will apply to:
• all new and existing directors
• persons with significant control (PSCs) and officers of relevant legal entities (RLEs)
• anyone delivering filings to CH unless using an authorised corporate service provider (ACSP)
Directors must be verified before their appointment for new incorporations, and existing directors must complete IV before their next confirmation statement date following 18 November 2025. Those who fail to verify cannot continue to act, their appointments will not be registered and persistent failure risks penalties and potential disqualification.
How verification works:
• Direct with Companies House: a digital process via app/portal using a valid photo ID, a self-taken photo and personal details. Overseas directors can use international passports but additional documentation may be required at CH’s request.
• Via an ACSP: regulated law or accountancy firms can verify identities and submit confirmations to CH. ACSPs must meet AML supervision and rigorous document-check standards and retain verification records for seven years.
The PSC regime and use of corporate directors are also subject to additional regulations. PSC and RLE officer verification will be mandatory from 18 November 2025, with CH implementing greater scrutiny of beneficial ownership accuracy. The use of corporate directors will be heavily restricted and only companies meeting prescribed conditions (e.g. whose directors are verified natural persons) may act as corporate directors.
From April 2027 there will be changes to how financial statements are filed at Companies House.
• Small companies: abolition of abridged and filleted options. A full profit and loss account and a directors’ report will be required.
• Micro-entities: a profit and loss account will become mandatory (a directors’ report may not be required for the smallest).
• Digital only: paper filing via post or hand delivery will end; accounts must be filed digitally in iXBRL format via a CH approved software program. These changes materially increase public financial disclosure and will enable more automated cross-checking by CH and other agencies.
Actions to take now:
• Address and email: ensure your registered office meets the “appropriate address” test and your registered email is live and monitored.
• Identity verification: identify all individuals who will need IV from 18 November 2025. Begin gathering acceptable ID, especially for overseas directors. Consider using an ACSP for verification and filings.
• Prepare for 2027 accounts: engage early with auditors and software providers, plan for iXBRL, and assess stakeholder communications given greater P&L visibility.
• Strengthen governance: tighten filing calendars, maintain evidence packs for each submission, and train teams on responding quickly to CH queries. Consider engaging a law firm to provide company secretarial assistance with managing filings, answering queries on CH related issues and ensuring compliance with the ECCTA.
In summation, the ECCTA sets a new benchmark for transparency and accountability. Early preparation, particularly for identity verification and digital accounts, will reduce risk, avoid disruption and demonstrate strong governance to stakeholders. It is crucial to regularly monitor Companies House guidance as commencement regulations and practical standards continue to roll out and engage with legal advisors as appropriate to assist.
