Our first blog in this series gave an overview of the main reforms being brought in under the Economic Crime and Corporate Transparency Act 2023.  Our second blog explained the initial raft of changes that came into force on 4 March 2024.  These included new procedures for companies, as well as new powers for Companies House. 

In this blog, we update you on the expected timetable for the remaining reforms to be brought into force.  This timetable is dependent on suitable Parliamentary time and will be kept under review by the government.  We highlight the milestone dates below – as you’ll see, Autumn 2025 is a key date for companies watch out for!

Winter 2024

From Winter 2024, continuing into 2025, Companies House plans to expedite the striking-off of companies where the company has been formed for a false basis.  It will also be able to annotate the register in a wider range of circumstances (including where a director is disqualified but the relevant company fails to notify the registrar of their termination).

Spring 2025

By Spring 2025, Companies House should be able to carry out checks on authorised corporate service providers (ACSPs) to authorise them to carry out identity verification services. 

The plan is also for individuals to be allowed to verify their own identity with Companies House voluntarily if they wish.  At the time of writing, Companies House is carrying out user research to help them develop their new identity verification service.  They have made a short online form available for anyone who would like to help with the research.  They have specifically asked for help from directors or people with significant control (PSCs) who are non-UK nationals and hold non-biometric passports.  It’s encouraging to see that Companies House is planning ahead for the introduction of the new identification regime and seeking to address any difficulties that individuals might have with the process, especially those who don’t hold a UK passport and/or live overseas.

Companies House will also be able to receive and assess applications from individuals seeking to have their residential addresses suppressed from public disclosure in certain circumstances.

* Autumn 2025 *

Autumn 2025 will be an important date as it’s by this date that identity verification will be made compulsory on incorporation for new directors and new PSCs.  At the same time, a 12-month transition period will begin, during which more than 7 million existing directors and PSCs will be required to verify their identity – this will happen as part of the annual confirmation statement filing.

Spring 2026

By Spring 2026, Companies House will require identity verification for anyone seeking to file any document with the Regulator.  They will also require a third-party agent filing on behalf of a company to be registered as an ACSP.  The Regulator will also reject documents that are filed by a disqualified director on their own behalf.

End of 2026

By the end of 2026, it is expected that the transition period for requiring identity verification will have completed.  Companies House will then start compliance activity against those who have failed to verify their identity where they were required to do so.

Keep an eye out for further blogs from us.  As and when the above changes come into force, we will provide you with more detail on what these will look like in practice and how they will impact your company.

Read the first blog in this series, which highlights some of the key changes under the Act that are expected in 2024 and what these will mean for your company.

The second blog in this series explains the initial raft of changes that came into force on 4 March 2024.

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The material in this article is provided for guidance and general information only and is not intended to constitute legal or other professional advice upon which you should rely. In particular, the information should not be used as a substitute for a full and proper consultation with a suitably qualified professional. Please do contact the Bates Wells team if you require further information.