What this is: The Economic Crime and Corporate Transparency Act (ECCTA) continues to change Companies House compliance for Overseas Entities, Limited Partnerships (LPs), corporate filers, and others interacting with the register.
What this means: Some requirements, including identity verification for new directors, PSCs, and LLP members, are already live, while other changes, such as LP identity verification and annual confirmation statements for English and Welsh LPs, are still to come. Overseas Entities are also facing greater scrutiny of beneficial ownership information and updating obligations. Overall, the reforms point to tighter filing controls, stronger identity checks, and more active enforcement.
Overseas Entities
Overseas Entities registered on the UK’s Register of Overseas Entities are also directly affected by ECCTA reforms. While the core registration regime remains in place, Companies House has made clear that it will apply increased scrutiny to filings, data consistency, and ongoing compliance.
In particular, Overseas Entities should expect:
- Greater validation of beneficial ownership information
- Increased focus on annual updating statements
- Identity verification of its directors and reporting this to the Companies House the anniversary of the date the UK Establishment was opened.
As identity verification is rolled out more broadly, relevant officers and individuals associated with Overseas Entities should anticipate verification requirements becoming a practical prerequisite for ongoing interaction with Companies House.
For Overseas Entities with complex ownership chains or overseas controllers, early preparation and alignment with UK compliance expectations will be critical.
Limited Partnerships
Identity verification for limited partnerships is not yet mandatory, but it is firmly on the implementation roadmap. Companies House has confirmed that IDV will be introduced for LPs at a later phase of the ECCTA rollout, following the same model applied to companies and LLPs. While no fixed completion date has been published, LPs should expect IDV obligations to emerge as reforms progress through 2026, particularly for nominated directors of corporate general partners and individuals filing information on behalf of LPs.
LP‑specific identity verification requirements will:
- follow the same structure as companies and LLP
- include a transition period, not a single hard cut‑off
- be enforced via filing restrictions and penalties, not retrospective invalidation
LPs will need to provide Companies House with more information about their partners. Changes in partner details will need to be notified within 14 days. Limited Partnerships did not historically have an annual confirmation statement obligation. While ECCTA introduces a new requirement for LPs to file annual confirmation statements, this obligation has not yet commenced and will take effect only once the relevant secondary legislation is brought into force.
Unlike English LPs, Scottish LPs (SLPs):
- already operate under an annual confirmation model
- are not being introduced to confirmation statements for the first time
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Corporate Filers or Presenters
Under ECCTA, a filer (or presenter) is any individual or organisation that delivers documents to Companies House, including:
- company directors or officers filing themselves
- company secretaries or employees submitting filings
- third‑party agents such as ACSPs, accountants or lawyers
Companies House guidance is explicit that identity verification requirements extend beyond directors and PSCs to those delivering documents to the Registrar. This is expected to become mandatory from November 2026 (delayed from the expected start date of April 2026).
ECCTA implementation – What’s live vs what’s coming
| ECCTA Compliance | What’s live now | What’s confirmed and coming |
| Companies House role & powers | Companies House has enhanced powers to query, reject and remove information; annotate the register; share data with law enforcement; and impose civil penalties. | Further automation, data matching and compliance activity will continue through 2026–2027 as systems mature. |
| Registered office & email (companies) | Companies must have an “appropriate” registered office and a registered email address; unlawful purpose statements are required on incorporation and confirmation statements. | No material new obligations announced; focus shifts to enforcement and data quality. |
| Identity verification – directors & PSCs | Mandatory ID verification for new directors and PSCs is live; a transition period applies for existing directors and PSCs linked to confirmation statements. | Completion of the transition period for all existing directors and PSCs is expected by late 2026. |
| Identity verification – LLP members | ID verification applies to LLP members on the same basis as directors, with a transition period. | Completion of the transition period alongside directors and PSCs. |
| Identity verification – filers/presenters | Voluntary verification available; filing rules unchanged for now. | Mandatory ID verification for anyone delivering documents to Companies House, and ACSP-only third-party filing, no earlier than November 2026 (delayed from Spring 2026). |
| Authorised Corporate Service Providers (ACSPs) | ACSP registration is live for AML-supervised firms; ACSPs can already conduct ID verification. | Third-party will be restricted to registered ACSPs once presenter rules go live (no earlier than Nov 2026). |
| Overseas Entities (ROE) | Register remains live; Companies House is applying increased scrutiny to beneficial ownership data, updating statements and compliance quality. | Identity verification becomes a practical prerequisite for ongoing interaction as IDV is embedded across roles. |
| Scottish Limited Partnerships (SLPs) | Annual confirmation statement obligation already applies; SLPs operate under an established annual filing model. | Expanded disclosure, ACSP-based filing and enhanced enforcement once LP reforms are commenced. |
| English & Welsh Limited Partnerships (LPs) | No annual confirmation statement obligation yet; ID verification not yet mandatory. | New annual confirmation statements, expanded partner disclosures, ACSP filing and ID verification for key roles once secondary legislation is in force (expected through 2026). |
This article is provided for informational purposes only and should not be considered, or relied upon, as legal advice.
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