• The Financial Reporting Council publishes feedback to its discussion paper on UK digital reporting
• Companies House publishes a LinkedIn blog addressing frequently asked questions on identity verification and becoming an ACSP
• Companies House confirms that, from 31 July 2025, overseas entities on the Register of Overseas Entities will need to provide further historical ownership information

FRC publishes feedback from discussion on digital reporting

The Financial Reporting Council (FRC) has published a feedback statement in response to the discussion paper on digital reporting it published in August 2024.

In that paper, the FRC sought views on a range of topics, including the scope and extent of digital reporting requirements, assurance of digital reports, developments in XBRL taxonomies, and guidance needed by users.

The feedback statement sets out a summary of comments from 29 respondents to the discussion paper. Respondents recognised the benefits of collaboration between regulators and reporting businesses to address the challenges of digital reporting. However, they also highlighted trade-offs between meeting UK-specific reporting requirements and maintaining global comparability, and would like additional guidance and other support materials from a variety of sources.

As noted in its original discussion paper, the FRC will not be taking any specific decisions in response to feedback, but the comments received will inform policy thinking and ongoing service development.

Read the FRC’s feedback statement following its discussion paper on digital reporting (opens PDF)

Read the FRC’s original discussion paper on opportunities for the future of UK digital reporting (opens PDF)

Companies House publishes blog on identity verification and becoming an ACSP

Companies House has published a blog on LinkedIn addressing some frequently asked questions concerning how regulated persons in the UK can apply to become an authorised corporate service provider (ACSP) and conduct identity verification on individuals.

The Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023) introduces the concept of identity verification (IDV). From Autumn 2025, IDV will become mandatory for certain individuals, including company directors and persons with significant control (PSCs). Companies House has already launched a facility for individuals to complete IDV before then on a “voluntary basis”.

From Spring 2026, the ECCTA 2023 will also impose restrictions on who can file documents at Companies House. Broadly speaking, to make filings, an organisation will need to ensure at least one of its officers or employees has completed IDV or it will need to engage an authorised corporate service provider (ACSP) to do so on its behalf.

Key points from the blog include the following.

• A company secretary (as an officer of a company) will not need to register as an ACSP to file documents at Companies House on behalf of that company, although they will need to ensure they have completed IDV.
• Where a single individual or team carries out filings on behalf of a group of companies, some entity in the group (the blog specifically refers to the parent company) will need to apply to become an ACSP. This is because the individual or team will otherwise only be permitted to file on behalf of the specific entity that employs them.
• However, Companies House is also exploring the potential to make regulations to allow filings by other persons, such as employees of another company within a group structure. If implemented, this will be communicated “well in advance” of spring 2026.
• Once an individual completes IDV, they will not need to do so again in the future (unless the information provided as part of IDV was misleading, false or deceptive).

Read Companies House’s LinkedIn blog on identity verification and becoming an ACSP

Register of Overseas Entities: changes in beneficial owners for pre-2023 period must soon be disclosed

Companies House recently published an update to its guidance on the Register of Overseas Entities (ROE) regime.

The update states that, with effect from 31 July 2025, an overseas entity registered on the ROE will need to file (in its next annual update statement) details of any change in its beneficial owners that occurred between 28 February 2022 and (broadly) 31 January 2023 (or, if earlier, the date on which the entity registered on the ROE) (the pre-registration period).

This includes not only changes in the entity’s beneficial owners during the pre-registration period, but also changes during that period relating to trusts of which any of the entity’s beneficial owners was a trustee. This extends to beneficiaries, settlors, protectors and enforcers.

There will be a transitional period for entities whose next update statement is due between 31 July and 31 October 2025. These entities will be able to file the relevant information with their 2026 update statement instead.

The changes were introduced by the Economic Crime and Corporate Transparency Act 2023 and have been expected. However, notwithstanding Companies House’s update, we still await the secondary legislation bringing these changes into effect.

Read our separate in-depth piece on information to be filed in the Register of Overseas Entities regarding changes during the pre-registration period