In April we reported on the as yet unimplemented changes to company law under the Economic Crime and Corporate Transparency Act 2023 ("ECCTA 2023"). In that article we commented that we did not have any indication as to when those changes would be brought into force. However, on 16 October 2024 Companies House published an 'outline transition plan' giving a rough guide to the implementation timetable (see here).
The good news is that it appears that advisers, companies and relevant individuals will be given a reasonable amount of time to prepare for and implement the changes.
For background on each of the below headings, see our April article.
Identity verification
Companies House estimate that more than seven million directors and persons with significant control ("PSCs") will need to verify their identity. The plan is for individuals to be able to voluntarily verify their identity from spring 2025. By autumn 2025 identity verification is slated to become compulsory in relation to new companies and for new appointments for directors and PSCs. At the same time, a 12 month transition period will commence by the end of which all existing directors and PSCs must have verified their identity. This will be tied into the filing of annual confirmation statements.
By spring 2026 it will become compulsory for any individual who wishes to file a document at Companies House to have their identity verified.
No further details of the identity verification process are provided.
ACSPs
Companies House envisages that third party agents and advisers will be able to register as Authorised Corporate Service Providers ("ACSPs") and then start to verify the identities of individuals by spring 2025. No further details of the registration process are provided.
The requirement that third party agents be registered as ACSPs to file documents on behalf of others looks set to be introduced by spring 2026.
Filing at Companies House
As regards individuals and ACSPs, see above.
Companies House will start to reject documents delivered by disqualified directors by spring 2026.
Directors
See above in relation to identity verification.
Other
Companies House expect to be in a position to require increased information from limited partnerships (see our article also from April), by the end of next year.
Although the transition plan mentions accounts and the ban on corporate directors, it gives no indication of timeframe.
Conclusion
The dates in the transition plan only give a rough idea of the proposed timetable. Given most of the time periods are prefaced with "by" it is possible some of the requirements will be introduced sooner. However, it is noted that a host of secondary legislation is required and so the timetable is dependant on Parliamentary time and will be kept under review.
As far as what companies should be doing to prepare, the action points from our earlier articles remain valid.
If you require any further information, or specific advice, please contact our expert team.
