The ECCTA 2023 transformed Companies House from a passive filing cabinet into an active gatekeeper. Here's what changed, what's still rolling out, and what it means for anyone verifying UK beneficial ownership.
In This Guide
Why the ECCTA Matters for UBO Compliance Implementation Timeline: What's Live, What's Coming The Companies House Transformation Mandatory Identity Verification The PSC Register: Coverage and Limitations The Failure to Prevent Fraud Offence Register of Overseas Entities Scottish Limited Partnerships Reforms Expected in 2026–2027 What This Means for UBO Verification in Practice How the UK Compares Globally Frequently Asked Questions
Why the ECCTA Matters for UBO Compliance
For decades, Companies House operated on trust. You submitted a form. They filed it. No questions asked.
That system created a well-documented problem. Shell companies with fake directors. PO box addresses that led nowhere. Persons of Significant Control (PSCs) who existed only on paper. The UK's corporate registry became a tool for money laundering, sanctions evasion, and fraud.
The Economic Crime and Corporate Transparency Act 2023 (ECCTA) changed the rules. It gave Companies House the power to question filings, reject suspicious applications, verify identities, and share data with law enforcement.
The results in year one were significant. Between March 2024 and March 2025, Companies House queried and removed false or misleading information affecting over 100,000 companies . It rejected more than 10,200 suspicious applications . It cleaned up over 82,000 registered office addresses, 66,900 officer addresses, and 55,100 PSC addresses that turned out to be fake.
For compliance teams, KYB providers, and anyone relying on UK company data, this is a structural shift. The data coming out of Companies House is becoming more reliable. But the transition is messy. Some reforms are live. Others have been delayed. And there are significant gaps between what the law requires and what's actually enforced.
This guide walks through every major change, with current dates and practical implications.
ECCTA Implementation Timeline: What's Live, What's Coming
The ECCTA received Royal Assent on 26 October 2023. Its reforms are being rolled out in phases, with transitional periods stretching into 2027.
Date Reform Status
26 Oct 2023 ECCTA becomes law. Reformed identification principle (senior manager liability) comes into force. Live 4 Mar 2024 Companies House gains new powers: query filings, reject suspicious applications, require registered email, remove false information. Live May 2024 Additional powers: change registered office addresses, expanded data sharing with law enforcement. Live 1 Sep 2025 Failure to prevent fraud offence takes effect for large organisations (250+ employees, £36M+ turnover, or £18M+ assets). Live 18 Nov 2025 Mandatory identity verification begins for all new directors and PSCs. 12-month transition for existing directors/PSCs starts. Live 26 Jan 2026 Central register of members option removed. Companies must maintain local registers. Live 1 Feb 2026 Companies House filing fees increased. Digital incorporation now £100, confirmation statements £50. Live Spring 2026 Limited partnership reforms (transparency, filing requirements, ACSP-only filing). Expected Nov 2026 Mandatory IDV for presenters (anyone filing documents) and ACSP registration deadline. Existing director/PSC transition completes. Delayed from Spring 2026 Apr 2027 Software-only filing of accounts and streamlined accounts for small/micro entities. Under review — delayed
Key takeaway: The core reforms are live. Identity verification is happening now. But the full regime won't be complete until late 2027 at the earliest. If you're building compliance processes around UK company data, plan for a moving target.
The Companies House Transformation: From Passive Registry to Active Gatekeeper
Before the ECCTA, Companies House had limited ability to check what was submitted to it. If you filed a form saying John Smith was a director living at 123 Fake Street, that went on the public register. No verification. No follow-up questions.
Since March 2024, Companies House has had the power to:
Power What It Means in Practice
Query any filing Can ask for evidence or clarification before accepting a document. Applies to incorporations, appointments, confirmation statements, and any other submission. Reject suspicious applications Over 10,200 applications rejected in the first year. Previously, almost everything was accepted automatically. Remove false information False entries removed across 82,600 registered office addresses, 66,900 officer addresses, and 55,100 PSC addresses in year one. Require registered email Every company must have a registered email on file. Used for direct communication about compliance deadlines and reform updates. Share data with law enforcement Proactive data sharing with NCA, SFO, HMRC, and other agencies. Major shift from the previous reactive model. Cross-check information Planned capability to cross-reference filings with data from other public and private sector bodies.
Why this matters for UBO verification: The quality of UK PSC data is improving. Fake addresses are being purged. Unverified directors are being flagged. But this is a multi-year cleanup. Data pulled from Companies House today is more reliable than in 2023, but not yet fully verified.
Mandatory Identity Verification: The Biggest Change for UBO Data Quality
This is the reform that matters most for anyone tracing beneficial ownership in UK companies.
Since 18 November 2025, identity verification is mandatory for all new directors and PSCs at the point of incorporation. For existing directors and PSCs, a 12-month transition period is underway. Approximately 6 to 7 million individuals must verify their identity by mid-November 2026.
Who Must Verify
Category When IDV Is Required Status
New directors Before appointment can be registered Mandatory since Nov 2025 New PSCs At incorporation or first notification Mandatory since Nov 2025 Existing directors When company's next confirmation statement is due (rolling 12-month window) Transition — completing Nov 2026 Existing PSCs (non-director) By the 14th of their birth month on the register Transition — completing Nov 2026 LLP members Same rules as directors Mandatory since Nov 2025 Presenters (filing agents) Anyone delivering documents to Companies House Delayed to Nov 2026 ACSPs Third-party agents must register Delayed to Nov 2026 Corporate directors All directors of the corporate director must verify. Only UK entities permitted. Expected end of 2026
How Verification Works
Directors and PSCs verify through one of two routes:
Route 1: GOV.UK One Login (free). App-based biometric verification using government-issued photo ID. Can also be done in person at Post Office locations. Over 1 million individuals verified during the voluntary period before November 2025.
Route 2: Authorised Corporate Service Provider (ACSP). A UK-supervised firm registered with Companies House can verify on a client's behalf. Useful for international directors who may not have UK-compatible ID.
What happens if you don't verify: Directors and PSCs who fail to verify commit a criminal offence. Companies with unverified directors on their board also commit an offence. Compliance activity against non-verifiers begins after the transition window closes.
Impact on UBO data: Before IDV, the PSC register relied on self-reported, unverified information. Anyone could claim to be a PSC with no proof of identity. The IDV rollout directly addresses this. As more individuals verify, the link between a natural person and their registered control of a UK company becomes significantly harder to fake. For automated UBO verification platforms, this means higher-confidence inputs when UK PSC data is part of the ownership chain.
The PSC Register: What It Covers and Its Limitations
The UK's PSC (Persons with Significant Control) register has been in place since 2016. It requires most UK companies to identify and report the individuals who ultimately own or control them.
Who Qualifies as a PSC
Condition Detail
Holds more than 25% of shares Directly or indirectly. Includes shares held through trusts and nominees. Holds more than 25% of voting rights Separately counted from shares. A person could hold 10% of shares but 30% of voting rights. Right to appoint/remove majority of directors Even without significant shareholding. Significant influence or control Catch-all provision. Covers de facto control without formal ownership. Control over a trust or firm meeting above Extends PSC obligations through trust and partnership structures.
Limitations of the PSC Register
The 25% threshold is high by international standards. India uses 10%. South Africa uses 5% for listed entities. The EU's 6th Anti-Money Laundering Directive allows member states to lower to 15% for high-risk sectors.
Complex ownership chains across jurisdictions can obscure the real UBO. A PSC might be a holding company registered in the BVI, which itself is controlled by a trust in Jersey. The PSC register shows the immediate parent. It doesn't automatically resolve the full ownership chain.
The ECCTA strengthens the register but doesn't change the threshold. What it does change is the enforcement behind it. Verified identities. Active querying of suspicious entries. And data sharing with agencies that can investigate further.
The Failure to Prevent Fraud Offence
Since 1 September 2025, large organisations incorporated in the UK face criminal liability if an associated person commits a specified fraud offence intended to benefit the organisation, and the organisation did not have reasonable prevention procedures in place.
Who It Applies To
Large organisations meeting at least two of: more than 250 employees, more than £36 million turnover, or more than £18 million in assets. This includes UK subsidiaries of multinational corporations.
What "Reasonable Procedures" Look Like
The UK government published statutory guidance in November 2024 based on six principles: top-level commitment, risk assessment, proportionate risk-based prevention procedures, due diligence, communication and training, and monitoring and review.
The guidance explicitly states that having a documented risk assessment is central to the defence. Organisations that haven't even conducted a risk assessment will find it very difficult to argue they had reasonable procedures.
UBO connection: Know-your-business and beneficial ownership verification are directly relevant to fraud prevention. If your organisation onboards a supplier or counterparty without verifying who actually controls it, and that entity is later involved in fraud benefiting your organisation, the failure to verify ownership could undermine your "reasonable procedures" defence.
Register of Overseas Entities: UBO Requirements for Foreign Companies
The Register of Overseas Entities (ROE) was created by the Economic Crime (Transparency and Enforcement) Act 2022 and went live on 1 August 2022. The ECCTA amended and strengthened it.
Any overseas entity that wants to buy, sell, lease (over 7 years), or transfer land or property in the UK must register its beneficial owners and managing officers with Companies House.
What Must Be Disclosed
Information Detail
Entity details Name, country of formation, registered office, correspondence address, email, public registration numbers. Beneficial owners Name, date of birth, nationality, residential address, nature and extent of beneficial interest. Managing officers Name, date of birth, nationality, correspondence address, role and responsibilities. UK-regulated agent Name, address, AML number, supervisory body. Agent must have completed AML checks. Annual update Entities must file annually confirming or correcting their registered information.
The ROE is particularly relevant for tracing UBO in UK real estate. Foreign entities holding UK property that haven't registered face restrictions on buying, selling, or leasing land. Directors can face criminal liability for non-compliance.
Scottish Limited Partnerships: Closing the Loophole
Scottish Limited Partnerships (SLPs) were a preferred vehicle for laundering money through the UK. An SLP could be formed with corporate partners — often registered in opaque jurisdictions like the Seychelles or BVI — creating a legal entity with no identifiable human being behind it.
The ECCTA closed this loophole. SLPs now have the same PSC reporting obligations as standard UK companies. Broader reforms to limited partnerships, expected no sooner than spring 2026, will require registration through an ACSP, mandatory financial information filing, and greater transparency around partners and their identities.
For compliance teams screening UK entities, SLPs should still be treated as elevated risk until the full LP reform package is in place.
What's Still Coming: Reforms Expected in 2026–2027
Reform Expected Timeline and Impact
Mandatory IDV for presenters No earlier than November 2026. Anyone filing documents at Companies House must be verified. Closes the gap where unverified individuals could submit filings. ACSP registration deadline No earlier than November 2026. All third-party agents must register. Unregistered agents unable to file. Limited partnership reforms Spring 2026 or later. Transparency requirements, ACSP-only filing, mandatory financial disclosures. Corporate director restrictions End of 2026. Only UK corporate entities permitted. All directors must verify identity. Shareholder transparency Timeline under review. More detailed shareholder information on the register. Software-only accounts filing Delayed from April 2027. All accounts via commercial software with iXBRL tagging. Cross-checking with external databases Ongoing. Companies House will cross-reference filings with other public and private data sources.
What This Means for UBO Verification in Practice
The ECCTA doesn't just change UK law. It changes the quality and reliability of UK company data that feeds into your UBO verification process.
If You Rely on Companies House Data
The data is getting better. Verified identities, purged fake addresses, and active rejection of suspicious filings all improve the baseline. But the transition is incomplete. Roughly 6 million individuals are still working through the IDV process. Until November 2026, you'll have a mix of verified and unverified records.
Practical step: Flag any PSC or director record that hasn't yet been verified. Treat unverified records as requiring additional due diligence.
If You're a Lender or Financial Institution
Lenders are increasingly factoring ECCTA compliance into their due diligence. Facility agreements may now require borrowers to confirm that all directors and PSCs have completed identity verification. Representations and warranties may need updating to cover IDV compliance.
If You Operate Across Multiple Jurisdictions
The UK's 25% PSC threshold is only one piece of the puzzle. If you're tracing ownership across the EU (where 6AMLD takes effect in July 2026), the US (where the CTA's future is uncertain), or Asia-Pacific, you need jurisdiction-specific rules applied consistently.
Platforms like Zavia.ai connect directly to government registries — including Companies House — to pull verified PSC and corporate structure data in real time. When the source data improves (as it is now under the ECCTA), the downstream UBO resolution becomes more accurate. The combination of better registry data and AI-powered ownership tracing means fewer false positives and faster verification.
How the UK Compares: UBO Transparency Across Major Jurisdictions
Country Threshold Registry Public Access ID Verification Key Law
UK 25% PSC Register Free, public Mandatory (2025–26) ECCTA 2023 EU (6AMLD) 25% National BO registers Legitimate interest Varies by state 6AMLD (July 2026) US 25% FinCEN BOI Law enforcement only None CTA (paused) Singapore 25% RORC (ACRA) Law enforcement only At filing Companies Act UAE 25% National registry Regulators only At filing Cabinet Res 58/2020 India 10% MCA registry Limited public PAN/Aadhaar Companies Act 2013 Germany 25% Transparenzregister Legitimate interest At filing GwG Australia 25% Proposed N/A Pending AML/CTF reforms
The UK is among the most transparent regimes globally. Free public access to PSC data, combined with mandatory identity verification, puts it ahead of most jurisdictions. The main limitations are the 25% threshold (higher than India or South Africa) and the ongoing transition period before all records are verified.
Frequently Asked Questions
What is the Economic Crime and Corporate Transparency Act 2023?
The ECCTA is UK legislation that reforms Companies House, strengthens corporate criminal liability, and introduces mandatory identity verification for directors and PSCs. It aims to prevent the misuse of UK corporate structures for economic crime.
When did the ECCTA come into force?
The Act received Royal Assent on 26 October 2023. Reforms are being implemented in phases. The first Companies House powers went live on 4 March 2024. Identity verification became mandatory on 18 November 2025. Full implementation is expected to continue into 2027.
Who needs to verify their identity under the ECCTA?
All company directors, persons with significant control (PSCs), and LLP members must verify their identity with Companies House. From November 2026, anyone filing documents at Companies House (presenters) and third-party agents (ACSPs) must also be verified.
What is a Person with Significant Control (PSC)?
A PSC is any individual who holds more than 25% of a company's shares or voting rights, has the right to appoint or remove a majority of directors, or exercises significant influence or control over the company.
How does the ECCTA affect UBO verification?
It improves the reliability of UK PSC data by requiring identity verification, giving Companies House power to reject suspicious filings, and enabling active data sharing with law enforcement. For compliance teams, this means higher-quality inputs when tracing beneficial ownership through UK entities.
What is the failure to prevent fraud offence?
Since 1 September 2025, large UK organisations face criminal liability if an associated person commits fraud to benefit the organisation and the organisation did not have reasonable fraud prevention procedures. This offence is modelled on the UK's existing failure to prevent bribery offence.
Does the ECCTA apply to overseas companies?
The Register of Overseas Entities requires any overseas entity holding UK property to disclose its beneficial owners. The failure to prevent fraud offence applies to large organisations incorporated in the UK, including UK subsidiaries of international groups.
What changed about Scottish Limited Partnerships?
SLPs now have the same PSC reporting obligations as standard UK companies. Further reforms expected in spring 2026 will require SLPs to file through an ACSP, submit financial information, and provide greater transparency about partners.
How do I verify a UK company's beneficial owner?
Start with the PSC register at Companies House (free, public access). Cross-reference with the Register of Overseas Entities if the entity is foreign. Check whether directors and PSCs have been identity-verified. For complex ownership structures crossing multiple jurisdictions, use an automated UBO resolution platform that connects directly to government registries.
What is an Authorised Corporate Service Provider (ACSP)?
An ACSP is a UK-supervised firm (solicitor, accountant, company formation agent) registered with Companies House to provide identity verification and filing services on behalf of clients. From November 2026, only registered ACSPs will be able to file documents on behalf of companies.
