• The Government publishes its second progress report on implementing the Economic Crime and Corporate Transparency Act 2023, including its next steps
• Companies House signals its intention to step up monitoring and enforcement activity in the forthcoming year

Government sets out progress on economic crime and corporate transparency reforms

The Department for Business and Trade (DBT) has published its second progress report on the implementation of aspects of the Economic Crime and Corporate Transparency Act 2023 (the ECCTA).

The report supplements the Government’s first progress report (published in May 2024) and covers Parts 1 to 3 of the ECCTA, which implement reforms to company law and limited partnerships in the UK, as well as the UK’s Register of Overseas Entities (ROE).

It summarises progress already made under the ECCTA, as well as the Government’s plans for the remainder of 2025 and 2026. Key updates include the following.

Identity verification (IDV)

• Companies House has rolled out voluntary identity verification (IDV) procedures to enable individuals to verify their identity in advance of mandatory IDV coming into effect in the Autumn. You can read more about voluntary identity verification in our previous Corporate Law Update.
• It has also opened the facility for firms to register as an authorised corporate service provider (ACSP), enabling them to conduct IDV for individuals (and, in due course, to continue to file documents at Companies House on behalf of their clients).
• The Government is now working on extending IDV requirements to limited liability partnerships (LLPs), overseas companies and certain other types of company.

Other company and LLP law reforms

• New requirements have taken effect requiring companies and LLPs to ensure their registered office is at an “appropriate address” (which cannot be a PO box). Since March 2024, Companies House has used its new powers to change the address of 82,600 companies, and it has challenged 3,800 companies that are using a PO box as their registered office address.
• The Government introduced enhanced measures to protect residential addresses from public disclosure. This includes allowing an individual to suppress their residential address from disclosure if it has been used as the registered office of a company that has since been dissolved.
• The Government has also introduced draft legislation enabling individuals to protect more personal information at Companies House than is possible at present, including their signature and date of birth. You can read more about the proposals to allow individuals to suppress a greater range of personal information from public view at Companies House in our previous Corporate Law Update.

The Register of Overseas Entities (ROE)

• Companies House is working towards requiring overseas entities to provide details of changes to their beneficial owners in the period before they registered on the ROE. It recently announced that this would take effect from 31 July 2025, although we still await regulations bringing these new requirements into effect. You can read more about the new requirement to report on pre-registration changes in overseas entity beneficial owners in our separate in-depth piece.
• Companies House has also been taking enforcement action against overseas entities that fail to comply with the ROE regime. According to the report, it has now issued 4,800 warnings and 444 penalties for failures to register on the ROE, and 3,700 warnings and 111 penalties for failures to update information. However, Companies House intends to suspend issuing penalties for a period while it focusses on enforcing existing unpaid penalties.
• The Government has made regulations permitting access to information held in the ROE regarding trusts. (This information is currently private.) The regulations to achieve this have already been made, and the facility to apply to obtain trust information is scheduled to open in August 2025. Information will be available on application to Companies House.
• Finally, the report states that legislation is being developed to “verify the identity of trust owners”. The report provides no further detail on this.

Limited partnerships

• The Government is working towards commencing reforms to limited partnerships by the end of 2026. These will include new requirements for a UK limited partnership to provide a registered office in the UK, to file an annual confirmation statement (similar to companies and LLPs), and to use an ACSP to deliver documents to Companies House.

The report also provides an update on collaborative action by Companies House and the Insolvency Service to identify and deal with business entities seemingly linked to illicit activities.

Read the Government’s second progress report on implementing economic crime and corporate transparency reforms (opens PDF)

Companies House announces intention to strengthen monitoring and enforcement

Companies House has published its business plan for 2025/2026, outlining its key priorities for the forthcoming year.

The plan signals a clear intention to engage in more active monitoring and enforcement to “prevent, detect and disrupt” economic crime.

In particular, Companies House intends to target individuals and companies with the worst compliance, including by developing automated capabilities that utilise artificial intelligence.

The business plan specifically mentions removing companies that continue to fail to comply with their legal obligations. However, we can expect Companies House to use the range of enhanced powers it has gained under the Economic Crime and Corporate Transparency Act 2023. These include:

• enhanced powers to query information submitted to it and to raise specific questions before accepting a filing;
• the ability to shift a company’s registered office address if it is not an “appropriate address” (broadly, an address where documents can be received and acknowledged);
• powers to share more information with law enforcement agencies and regulatory bodies;
• a new power to levy financial penalties for offences committed under company law, as an alternative to issuing legal proceedings; and
• the ability to strike a company off the register if it was formed on a false basis.

The plan also reiterates Companies House’s plans for implementing other aspects of the Act, including identity verification (IDV), introducing restrictions on who can file documents at Companies House, and opening access to information on trusts held on the UK’s Register of Overseas Entities.

Read Companies House’s business plan for 2025/2026