Incoming changes to the Economic Corporate Crime and Transparency Act 2023 (ECCTA)

The Economic Corporate Crime and Transparency Act 2023 (ECCTA) was introduced on 26 October 2023 to strengthen corporate governance and tackle economic crime in the UK. Here is a summary of the next phase of changes to be aware of.

Identity verification

Soon it will become compulsory for directors/LLP members and Persons of Significant Control (Interested Persons) to verify their identity to Companies House to prove they are who they claim to be. Anyone that does not comply with identity verification requirements on time will not be able to make any filings for the company. There will be a range of consequences, including a financial penalty and being unable to start a new company.

From 8 April 2025, Interested Persons have been able to voluntarily verify their identity. Further details can be found here.

Interested Persons/LLP members/PSCs should verify their identity via the GOV.UK One Login at this link.

Once ID verification becomes compulsory (expected Autumn 2025) there is expected to be a 12-month transition period to complete ID verification for existing Interested Persons. Existing Interested Persons will typically need to confirm their ID has been verified as part of their company’s next Confirmation Statement filing. This connects their verified identity to their existing registrations.

We encourage any Interested Persons to verify their identity as soon as possible to avoid any delays once the requirement becomes mandatory.

In most cases Interested Persons will only need to verify their identity once, no matter how many entities they are connected to, and should not verify again unless requested to do so by Companies House.

What happens once ID has been verified?

Unique Identity Number (UIN): Once an Interested Person has successfully verified their identity with Companies House, they will be issued with a unique Companies House personal Code. This is an 11-character code that links their verified identity to Companies House records.

This code is crucial and should be kept secure. Your company secretary or outsourced company secretarial service provider will be requesting this in future, when needed to make filings, including accounts.

Verification statement: Once the individual uses their personal code to connect their verified identity to Companies House records, an identity verification statement will be shown on the public Companies House register. This signifies that the Interested Person’s identity has been verified.

Filings: Having a verified identity (and a UIN) will enable the Interested Person to comply with future mandatory filing requirements (including those made by a third party on behalf of an Interested Person). Without it, Interested Persons may face restrictions on filing or even forming new companies.

Interested Persons can share their personal code with trusted individuals (like accountants or company formation agents who are Authorised Corporate Service Providers (ACSPs)) to file documents on their behalf.

Failure to comply with identity verification requirements will be an offence and can lead to financial penalties, restrictions on company filings, and even criminal sanctions.

New financial penalties

To improve transparency and accountability, as part of their enhanced powers, Companies House now has the authority to impose financial penalties for breaches of the Companies Act 2006, such as:

• Failure to file or late filing of confirmation statement, annual accounts and other filings (previously only imposed on late filing of annual accounts), and
• Failure to maintain accurate books and registers.

Factors in penalty calculation:

• The severity of the offence,
• The frequency of the offences (repeated offenders face higher penalties), and
• Whether there was intent to deceive.

More serious offences could result in civil action, Interested Person disqualification or potentially even criminal prosecution. If convicted, an Interested Person could end up with a criminal record.

Interested Persons (and equivalents) are being encouraged to keep on top of their responsibilities ahead of new penalties being applied.

If you have any questions on the above, please get in touch by completing the form below.