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Changes to Kudocs on/ after 18 November 2025 – ECCTA & IDV

What will be changing in Kudocs after the latest ECCTA/ IDV changes are implemented on 18 November 2025?  A lot will change in the background, but hopefully our users won’t notice much – at least, that is the intention!

The ECCTA/IDV changes are significant, but will mostly be seen in specific company and LLP processes where proof of ID verification (IDV) is relevant.  These are:

  • incorporating a new entity;
  • appointing a new director or LLP member;
  • notifying a new PSC;
  • filing your first confirmation statement after 18 November 2025; and
  • filing a UID (or ‘Personal Code’) at Companies House for an existing PSC.

We’ve made all the necessary changes to Kudocs to make this work. For the most part, all you’ll have to do is enter UIDs for certain stakeholders in certain processes. For more information, see our guide here.

How will the confirmation statement process change?   There will be a few minor changes to the confirmation statement process. This is because the first confirmation statement filed after 18 November 2025 must include the UID for each and every existing director or LLP member. This is the final step of IDV, confirming that this has been completed for the relevant individual(s).

To help with this, Kudocs will flag if UIDs are missing from relevant stakeholders and you will be required to file a full confirmation statement for the first filing made after 18 November 2025.  This is to comply with Companies House requirements. Anything less will be automatically rejected by Companies House, so to save time we will check that your filings are compliant before you can submit them.

You can store director/LLP member UIDs in Kudocs in advance of filing the confirmation statement, or you can add these during the confirmation statement preparation process – see here for more.  You will be unable to submit the confirmation statement if a required UID is missing.

PSC UIDs do not need to be provided at the same time as the confirmation statement. Instead, you will need to submit the PSC UID within a certain time period (again, easy to do via Kudocs). The rules are a bit confusing, but in short:

  • PSCs who are directors must file within a 14-day window, starting with the day after the confirmation statement date as ‘locked in’ at 18 November 2025, and finishing by the filing deadline for that ‘locked in’ confirmation statement date.
  • PSCs who are not directors must file within a 14-day window running from the 1st to the 14th day of their birth month.

Read here to find out more!

The requirement to include UIDs in the first confirmation statement only applies to entities that existed before 18 November 2025, and only to the first confirmation statement filed after 18 November 2025.  Again, you don’t have to worry about this – Kudocs will automatically detect what has happened and what needs to be filed (or not), and prompt you as needed.

How will the incorporation process change?  All incorporations after 18  November 2025 must include the UID of each director or LLP member.  You will be unable to submit an incorporation without this information.  The incorporation process will therefore look slightly different to before as UID will be a new, mandatory, field for directors and LLP members.

PSCs must also provide their UID either as part of the incorporation process or, if not, within 14 days of incorporation.  If you do not provide the PSC UID to Companies House as part of the incorporation, Kudocs will show a reminder and alert on the entity dashboard to remind you to file it.

How will the ‘appoint director’ process change?  All new director appointments filed after 18 November 2025 must include the new director’s UID.  You will be unable to process a director appointment in Kudocs without this information.  The appointment process will therefore look slightly different to before as UID will be a new, mandatory, field.

How will the edit director process change?  There will be no change to this process. You may notice that ‘occupation’ is no longer a mandatory field.

How will the ‘appoint new LLP member’ process change?  All new member appointments filed after 18 November 2025 must include the UID of the member.  You will be unable to process a member appointment in Kudocs without this information.  The appointment process will therefore look slightly different to before as UID will be a new, mandatory, field.

How will the notify new PSC process change?  All new PSC notifications filed after 18 November 2025 must include that PSC’s UID.  You will be unable to process a PSC notification appointment in Kudocs without this information.  Also, because of changes around what information needs to be stored within internal company registers (see here), PSC notifications and changes no longer have a “Register Entry Date”.  This is now called the “Information Confirmed Date”, being the date on which the PSC/RLE/ORP confirmed that they qualify as such and provided their details to the relevant company/LLP.

The notification process for individual PSCs will therefore look slightly different to before. UID will be a new, mandatory, field and there will also be an “Information Confirmed Date” field instead of the “Register Entry Date”.

How will the notify new RLE/ORP process change?  There will be no change to this process – yet!  We know that at some point, there will be a requirement for RLE/ORPs to verify their identity under ECCTA. However, this requirement – or the exact mechanics of how it will work – has not yet been confirmed by Companies House.

How will I be able to submit PSC UIDs to Companies House?  This will be easy to do using Kudocs.  As above, the timings to submit a PSC UID depend on whether the PSC is just a PSC, or a PSC and director/ LLP member (see here for more information).

As long as you have added the UID to Kudocs, there are 3 ways to submit this to Companies House (provided it is the correct time to do so!):

1. From the entity dashboard in the UID pop up.

2. From the PSC’s own stakeholder page in the entity.

3. Automatic submission by Kudocs within the relevant window, if you have selected automatic PSC UID filing as explained here.

How will I be able to submit director and LLP member UIDs to Companies House?  Existing directors and LLP members will submit their UIDs via the first confirmation statement filed after 18 November 2025 for the relevant entity (see above).  So all you need to do is file the confirmation statement when needed. If you decide to file an early confirmation statement after 18 November 2025, this will also trigger the UID requirement.

When you appoint a new director or LLP member, you must provide their UID as part of the appointment process.

When you appoint a new director or LLP member as part of an incorporation, you must provide their UID as part of the incorporation.

When I onboard a new entity to Kudocs, if the directors/ PSCs/ LLP members have already submitted their UIDs to Companies House, will that information be added to Kudocs?  As far as we are aware from the information provided by Companies House, UIDs of existing directors will NOT be information that can be accessed either publicly or privately (i.e. by using the company’s authentication code).  We are still waiting for further confirmation from Companies House about this.

If the UID is not provided by Companies House during onboarding, then you will still be able to manually add that information to Kudocs for completeness. However, it is worth noting that if the UIDs have already been submitted to Companies House, there is no need to add that information to Kudocs unless it is for a stakeholder who will become a new director/PSC/LLP member after onboarding.

I want to preview the changes I have made on a paper/ pdf form.  Why can I not see the latest information on the form in Kudocs?  At the time of writing, Companies House has not yet published paper forms in line with the 18 November 2025 changes.  Therefore, sections like the ID verification statement or the updated date fields on PSC filings will NOT currently show on the previews available in Kudocs.  We will update these preview documents as soon as Companies House releases updated versions of the relevant forms.

Do not worry – the fact that the preview document does not contain this information does not mean that it is missing from the actual filing by Kudocs!  The actual electronic submission by Kudocs to Companies House will be fully up to date.

Will the paper/ pdf forms of the relevant filings be updated to reflect these changes?  Our understanding is that certain forms (such as AP01, LLAP01, PSC01, PSC02, etc.) will be updated by Companies House in due course.  They have not yet published new versions in time for deployment of the 18 November 2025 changes. We will keep an eye out for any new versions released thereafter and update Kudocs accordingly.

However, it does not matter that the preview form in Kudocs (or indeed any other paper form) does not include the new changes.  The electronic data submissions sent by Kudocs to Companies House will still be correct and up to date in line with Companies House requirements.

At the time of writing, we understand that Companies House will not publish any paper form for the PSC UID filing as in the vast majority of cases this can only be done online. See below for an exception to this!

We have a PSC whose personal information is protected from showing at Companies House – what do we do?

You/the PSC will need to submit their UID via a special (paper) filing route. Please contact Kudocs for further guidance

 

Last updated: 18/11/2025 by Kudocs Admin

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