Published: 22 July 2025 11:19 am  Author: Oliver Stanley

ECCTA Update – implementation plans etc (July 2025)

As you will have seen, Companies House is modifying how it works in light of the Economic Crime and Corporate Transparency Act 2023 (ECCTA) changes. This includes how and what information is filed with Companies House.

Some changes have already come into force (e.g. registered email addresses) and the next big change includes Identity Verification (IDV).  Companies House has already launched some of its IDV services (see our blog for more information) and the next big implementation is due in Autumn 2025 (exact timings and details are still to be confirmed by Companies House). 

This is what we know so far.

 

IDV and UID to become compulsory

You (or your clients) can already – optionally – complete IDV and obtain a ‘Personal Code’ from Companies House.  This Personal Code is also known as a ‘Unique Identifier (UID).

All new and existing directors, LLP members and PSCs will need a UID in order to submit certain key filings to Companies House:

• All new directors, LLP members and PSCs must include their UID when being added to a company/LLP.  This means all incorporations, appointments and notifications will require the UID.
• All existing directors, LLP members and PSCs must include their UID when their company/LLP submits its first confirmation statement after the Autumn 2025. 

Submitting a UID to Companies House is how Companies House will verify the identity of the relevant individual.  It allows Companies House to link the UID to their existing records of the director/LLP member/PSC.  Companies House have suggested that it will update the public record of the individual to show that they have passed IDV – we are awaiting further information on this.

 

Incorporations

The key change will be the requirement to provide UIDs for all directors, LLP members and PSCs. The IDV status should then be shown at Companies House when the new company or LLP is formed. 

Companies House will also remove the authentication method from incorporations (using 3 partial personal attributes, e.g. first three letters of mother’s maiden name) and replace it with a tick box confirming authentication.

Again, Kudocs will adjust its processes to support these changes.

If you do not have the UID for an individual, you will not be able to submit the relevant filing to Companies House after Autumn 2025.  It is very important that IDV is completed by all necessary individuals to prevent delays in filing confirmation statements, incorporating new companies and adding new stakeholders.  Don’t delay!

Kudocs has already begun making updates and will make all necessary changes to ensure that the transition to these new requirements is easy.  You will notice a few small changes to our processes (such as requiring the UID), but these will be minimal.

 

Director occupation no longer required

Directors will no longer be required to provide their occupation to Companies House when recording their appointment or changing details. 

This field will be removed from the filings that are submitted to Companies House.   Kudocs will likely still keep existing occupation data, but will remove the mandatory requirement to provide this for new director appointments or incorporations. 

 

Registers

Two major changes around company registers are due to come into force from Autumn 2025. 

 

(i) Abolition of legal requirement to maintain (some) company registers

Companies will no longer be legally required to keep their own:

• Register of Directors
• Register of Directors’ Residential Addresses
• Register of Secretaries
• PSC/RLE/ORP Register

Only the Register of Members will be legally required as an internal company register (i.e. in Kudocs).   

However, we expect all/ most companies still to keep their own non-statutory registers – just as many companies opt to keep Registers of Allotments, Transfers, etc despite these not being legal requirements.  Given the need to access and review company information quickly and easily, and the ease with which you can do this using Kudocs, Kudocs will therefore not be removing any registers from the system.  It will be much faster and easier to look up (e.g.) director information using Kudocs, than checking Companies House.  Furthermore, a company will still need to provide Kudocs with details of officers and PSC/RLE/ORPs in order to submit that information to Companies House, so it makes sense for Kudocs to retain this information in the existing register format.

 

(ii) Removal of the Companies House Central Register option

Since 2016, companies could choose to keep certain registers on the Companies House ‘central register’ instead of as separate internal records.  This option will be removed by ECCTA – initially for the registers which will no longer be legally required.  This is logical because, if the legal requirement is only to keep officer and PSC/RLE/ORP details at Companies House, there is no need to elect to keep that information at Companies House!

The timings are still unclear for dealing with companies who have previously opted to keep their Registers of Members at Companies House only.  Please contact Kudocs for further guidance (including bringing your registers into Kudocs instead!). 

 

LLP Registers

LLPs have the similar – current – requirements to keep their own registers i.e. of LLP members and PSCs. 

The above two changes may also affect LLPs from Autumn 2025, but this has not yet been confirmed.  We are still waiting for further details – watch this space! 

 

When are these changes coming into effect?

The latest information we have from Companies House is “Autumn 2025”.  What that means exactly is not yet clear.  The new technical documentation has been released (which we are using to start updating our system), so Companies House is moving forward.

As soon as we have a confirmed go live date we will let you know in our blog and via other channels.

 

Is Kudocs ready for the changes?

Yes!  We have already started implementing changes in the live system, but some of them can only go live once Companies House makes the changes live at their end.  Kudocs will be ready though!

 

How can I find out more?

• On our website and in our blog
• Get in touch with us – we’re always happy to help and share what we know
• On the Companies House website

We will also be running a panel discussion with cosec and ECCTA experts later in August.  We’ll be in touch with more information, but sign up to our newsletter to ensure you remain in the loop.