Economic Crime and Corporate Transparency Act 2023 – some dates for your diary
Companies House recently published a policy paper setting out its indicative timetable for the phased implementation of the changes which the Economic Crime and Corporate Transparency Act 2023 (ECCTA) brought about.
The government anticipate that around 50 statutory instruments will be required to bring these changes to fruition and so completion is not envisaged to occur until 2027, depending on Parliamentary time in both the House of Commons and the Lords.
The main time frames to note are as follows:
From now until early 2025
Companies House should be able to:
- Expedite the striking off of companies which have been formed on a false basis
- Make amendments to the register in cases where a director has been disqualified but not terminated his appointment on the Companies House register
Spring 2025
Companies House should be able to:
- Carry out checks on Authorised Corporate Service Providers (ACSPs) to authorise them to carry out verification services. The introduction of identity verification was a key component of ECCTA whereby all directors, people with significant control (PSCs) and those who file on behalf of companies will need to have their identities verified.
- Allow individuals to verify their identity on a voluntary basis.
- Allow individuals to apply to have their residential addresses hidden from public disclosure in certain circumstances.
Autumn 2025
Companies House should be able to:
- Make identity verification compulsory for new companies and new appointments of directors and new PSCs.
- The transition phase will begin to require all existing directors to verify their identities, which at present is thought to number 7 million people. It is envisaged this will be introduced as part of the annual confirmation statement filing.
Spring 2026
Companies House should be able to:
- Require identity verification on filing any document.
- Require third parties to be registered as an ASCP.
- Reject documents filed by disqualified directors.
By the end of 2026
Companies House should be able to:
- Require all limited partnerships to submit more information to give greater transparency on the public register.
- Complete the transition period so that all individuals have had their identity verified and begin sanctioning those who have not done so.
- Facilitate greater information sharing and cross checking across public and private sectors bodies.
In summary, the timetable remains very much aspirational but this recent paper at least outlines which changes are due to be implemented first, so that companies and third party providers to companies can begin to consider their options.
If you have any questions on this or any other corporate and commercial matter, please contact our team by emailing enquiries@tsplegal.com