Where the Act stands
The Economic Crime and Corporate Transparency Act 2023 (ECCTA) is being brought into force in phases, and several of its requirements already apply to businesses. A corporate criminal offence of failing to prevent fraud has applied to large organisations since 1 September 2025, and identity verification has been compulsory for new directors and people with significant control (PSCs) since 18 November 2025. Further changes to Companies House filings, registers and powers are scheduled between now and April 2028.
The government’s latest update came on 23 October 2026. It confirmed that software-only filing of annual accounts starts in April 2028, and paused the requirement for small companies and micro-entities to file profit and loss accounts. Companies House’s transition plan, as updated that day, puts identity verification for anyone filing a document, and the requirement for filing agents to be authorised, at no earlier than November 2027.
The reforms respond to a problem Companies House has tried to measure. Companies House’s 2026–27 Strategic Intelligence Assessment, cited in the government’s June 2026 progress report, suggests that around 50% of register abuse relates to fraud and another 25% to illicit finance. In the year to 31 March 2026, Companies House used its new powers to address compliance issues with about 158,000 companies.
What the Economic Crime and Corporate Transparency Act covers
The Act has six Parts. The table below covers the strands that affect most businesses, who each applies to and where it stands at 29 October 2026. Sources are the Home Office guidance on failure to prevent fraud, Companies House’s transition plan and the government’s 23 October 2026 accounts statement.
| Strand | What it does | Who it affects | Where it stands |
| Failure to prevent fraud | Makes a large organisation criminally liable if an employee, agent, subsidiary undertaking or other associated person commits a specified fraud intending to benefit it, unless it had reasonable fraud prevention procedures | Incorporated bodies and partnerships meeting two of three tests: over 250 employees, over £36 million turnover, over £18 million total assets. Incorporated charities are included | In force since 1 September 2025 |
| Companies House powers | Lets Companies House query and reject filings, remove inaccurate information, issue financial penalties and share data with law enforcement | Companies and LLPs | In force; most powers from 4 March 2024, penalties from October 2024 |
| Identity verification of directors and PSCs | Requires directors and PSCs to verify their identity; verified status is published on the register | Every director and PSC | Compulsory for new appointments since 18 November 2025; 12-month transition for existing ones |
| Registers | Ends the option to hold member information on the central register; removes the need for local registers of directors, secretaries and PSCs | Companies | In force since November 2025 and January 2026 |
| Filers and filing agents | Requires identity verification for anyone filing a document, and third-party agents to be registered as Authorised Corporate Service Providers (ACSPs) | Anyone who files, including advisers filing for clients | No earlier than November 2027, with at least six months’ notice |
| Annual accounts | Software-only filing in iXBRL; a strengthened audit exemption statement; component parts filed together; a limit on shortening accounting reference periods | All companies | April 2028; the profit and loss filing requirement for small companies and micro-entities is paused |
| Limited partnerships | Requires more information on partners, a registered office and email address, a lawful purpose statement and an annual confirmation statement | Limited partnerships | No earlier than the end of 2026 |
| Register of Overseas Entities | Requires overseas entities that own or want to own UK land to register their beneficial owners; trust information can be requested from Companies House | Overseas entities with UK property | In force; trust disclosure service since 31 August 2025 |
What is already in force
Failure to prevent fraud
Since 1 September 2025, a large organisation can be prosecuted if an employee, agent, subsidiary undertaking or other person providing services for or on its behalf commits a specified fraud intending to benefit it. The Home Office guidance says it does not have to be shown that directors or senior managers ordered or knew about the fraud. The organisation’s defence is to show it had reasonable fraud prevention procedures in place, and the burden of proof is on the organisation, on the balance of probabilities.
The guidance builds those procedures around six principles: top-level commitment, risk assessment, proportionate risk-based procedures, due diligence, communication and training, and monitoring and review.
Smaller businesses are not directly in scope. The guidance does say that a small organisation can be an associated person while it provides services for or on behalf of a large one, and may face contractual requirements from that customer. It also says an audit alone cannot constitute a defence, because audits are not designed to identify all frauds.
Identity verification and Companies House data
Identity verification became compulsory for new directors and PSCs on 18 November 2025. Existing directors and PSCs verify within a 12-month transition period, predominantly aligned to the due date of the company’s next confirmation statement. Verification is a two-step process: the individual completes an identity check, either directly with Companies House or through an authorised agent, receives a personal code, then links that code to each of their appointments. The company confirms its directors have passed the check when it files the confirmation statement, and verified status is published on the register.
The government’s third progress report, published in June 2026, gives the position at 31 March 2026:
- Companies House had issued 3.81 million personal codes, linked to 3.74 million appointments, and expected to verify 6–7 million individuals by November 2026.
- Authorised agents had verified 783,000 individuals.
- Companies House had sent two million email nudges ahead of confirmation statement deadlines and more than three quarters of a million default letters. Casework had begun that could lead to financial penalties and court proceedings, and some cases had been referred to the Insolvency Service.
- In an earlier pilot on late confirmation statements, 1,354 companies received penalty warnings between February and November 2025, and 66% of them went on to receive a penalty notice.
That last figure shows the direction of enforcement. A reminder from Companies House is followed by a penalty more often than not.
Two other changes are already live. From January 2026, companies can no longer hold information about their members on the central register at Companies House. Since November 2025, companies have also no longer needed to keep separate local registers of directors, secretaries and PSCs.
What has moved
Identity verification for filers and agents
Companies House’s updated transition plan puts two linked requirements at no earlier than November 2027. Whoever delivers a document to Companies House will have to have had their identity verified, and third-party agents filing on behalf of companies will have to be registered as Authorised Corporate Service Providers (ACSPs). Companies House has committed to give at least six months’ notice before either takes effect.
ACSPs must be based in the UK and supervised under the UK’s anti-money laundering regime. Companies House can cease or suspend those that fall short: at 31 March 2026 it had ceased 56 and suspended 74, according to the progress report. The practical point for businesses that use an adviser to file confirmation statements or other documents is that the adviser will need to be on that register.
Accounts filing
In a statement on 23 October 2026, the government confirmed that from April 2028 all UK companies must file their accounts in iXBRL format using commercial software. This applies to companies that file their own accounts and to those that use an agent. Companies House’s web and paper routes will close for accounts, but remain available for confirmation statements and updates to director details.
What has changed is the profit and loss requirement. Following the Small Business Regulatory Taskforce’s recommendations, the government has paused plans for small companies and micro-entities to file profit and loss accounts. After 1 April 2028 they can continue to file abridged accounts and to remove, or ‘fillet’, profit and loss information from the accounts filed.
Three further accounts changes remain scheduled for April 2028:
- a strengthened eligibility statement for every company claiming an audit exemption
- a requirement to file the component parts of accounts and reports together
- a limit on how many times a company can shorten its accounting reference period
Other changes still to come
By no earlier than the end of 2026, Companies House expects to require all limited partnerships to submit more information, to start compliance activity against individuals who have not verified their identity, and to reject documents delivered by disqualified directors, other than certain filings made through an ACSP.
Key dates for ECCTA
The table follows the outline transition plan Companies House updated on 23 October 2026. Dates for future changes are Companies House’s indicative timetable, which it says depends on Parliamentary time and is kept under review.
| Date | What changes | Status |
| 4 March 2024 | Companies House can query and reject filings; companies must provide a registered email address and confirm their activities are lawful | In force |
| 18 March 2025 | Agents can register as Authorised Corporate Service Providers (ACSPs) | In force |
| 8 April 2025 | Individuals can verify their identity voluntarily | In force |
| 1 September 2025 | Failure to prevent fraud offence applies to large organisations | In force |
| 18 November 2025 | Identity verification compulsory for new directors and PSCs; 12-month transition begins for existing ones | In force |
| January 2026 | Companies can no longer hold member information on the central register | In force |
| November 2026 | The 12-month transition for existing directors and PSCs ends | Expected |
| No earlier than the end of 2026 | Compliance activity against unverified individuals; more information required from limited partnerships; documents from disqualified directors rejected | Expected |
| No earlier than November 2027 | Identity verification for anyone filing a document; third-party agents must be ACSPs (at least six months’ notice) | Expected |
| April 2028 | Software-only filing of annual accounts; strengthened audit exemption statement; component parts filed together; limit on shortening accounting reference periods | Confirmed 23 October 2026 |
| After 1 April 2028 | Small companies and micro-entities can keep filing abridged accounts and filleting profit and loss information | Profit and loss requirement paused |
What businesses and owners should do, and when
The actions below are grouped by when they fall due. The first group applies to almost every company, while the fraud prevention items apply to large organisations and the businesses that supply them.
Now
- Directors and PSCs: verify your identity if you have not. The transition year for existing directors and PSCs runs to November 2026, and verification is predominantly aligned to the next confirmation statement. Owners with several directorships complete the check once and link the personal code to each appointment.
- Keep the registered email address current and monitored. Companies House uses it for filing reminders and compliance notices, and its transition plan asks companies to check it is correct.
- Large organisations: assess your fraud risk. Check whether you meet two of the three tests (over 250 employees, over £36 million turnover, over £18 million total assets), counting subsidiary undertakings. If you do, the Home Office guidance expects a documented risk assessment, reviewed typically every one to two years, and a record of any decision not to act on a risk.
- Suppliers and advisers to large organisations: expect contract terms. The guidance says smaller organisations providing services for or on behalf of a large one may face contractual fraud prevention requirements.
- Companies that used the central register of members: hold your own. The option ended in January 2026.
- Overseas entities that own UK land: keep your entry up to date. Entities that fail to comply cannot easily sell, lease or raise finance over their property.
By the end of 2026
- Confirm every director and PSC has verified. Companies House expects to begin compliance activity against unverified individuals from the end of 2026 at the earliest.
- Limited partnerships: gather partner details. Companies House expects to require more information from limited partnerships from the same point, including partners’ details, a registered office and email address, a lawful purpose statement and an annual confirmation statement.
During 2027
- If an adviser files for you, ask about ACSP registration. Identity verification for filers and the ACSP requirement for agents come in no earlier than November 2027, with at least six months’ notice.
- Start choosing accounts software. There is no web or paper route for accounts from April 2028, so a year’s lead time suits a change of system.
Before April 2028
- File accounts in iXBRL using commercial software. This applies whether you file yourself or through an agent. Companies House lists software providers on GOV.UK.
- If you claim audit exemption, expect a fuller statement. Companies near the thresholds can talk to our audit and assurance team well before then.
- Plan year-ends. The limit on shortening accounting reference periods and the requirement to file the component parts of accounts together both start in April 2028.
Companies House has shown why accuracy in accounts matters. The progress report describes five companies shut down by the High Court after filing false or forged accounts claiming turnovers of up to £642 million, and falsely naming reputable accountants and solicitors as their auditors.
Frequently asked questions about ECCTA
Does the failure to prevent fraud offence apply to us?
It applies to incorporated bodies and partnerships that meet two of three tests in the financial year before the fraud: over 250 employees, over £36 million turnover and over £18 million total assets. The tests are applied across the whole group, including subsidiary undertakings. Smaller organisations are not directly in scope, although the Home Office guidance says its principles are good practice that may help them too.
Do all directors have to verify their identity?
Yes. Directors and PSCs of new companies verify at incorporation, and new appointments verify when they are made. Existing directors and PSCs verify during the 12-month transition period that began on 18 November 2025. The progress report says the requirements have also been extended to LLPs, overseas companies and unregistered companies.
Is the November 2027 date for filers confirmed?
No. Companies House describes it as ‘no earlier than’ and has committed to at least six months’ notice before the requirements take effect.
Do small companies have to file profit and loss accounts from April 2028?
The government has paused that requirement. After 1 April 2028, small companies and micro-entities can continue to file abridged accounts and to remove profit and loss information from the accounts they file. Software-only filing still applies to them.
What happens if a director does not verify?
Companies House’s approach starts with information and reminder emails, and gives companies the chance to explain exceptional circumstances. Where companies fail to complete verification within reasonable timeframes, it says it will use financial penalties, prosecution and referral to other agencies.
Does software filing apply if an accountant files our accounts?
Yes. The government’s statement says the requirement applies to companies that file their own accounts and to those that use an agent.
Speak to us
If you are unsure whether your directors, PSCs or filing arrangements are ready, contact Taylor Rogers as below, or you can call our Manchester office on 0161 399 0121 or our Liverpool office on 0151 303 3112.
Dates are correct as at 29 October 2026 and reflect Companies House’s indicative timetable, which it keeps under review.