30 August 2024

Companies House has recently issued their latest Corporate Business Plan, which sets out its aims and proposals for April 2024 to March 2025. Many of this year’s plans follow the recent coming into force of the Economic Crime and Corporate Transparency Act 2023, which has granted the Registrar enhanced statutory powers aimed to assist in the reduction of economic crime within the UK.

For businesses, the key changes outlined within the Plan include:

• The ‘cleaning up’ of existing information held by Companies House on the Register, through the removal of inaccurate information. Information provided on behalf of a company will be queried and/or rejected by Companies House where this is considered by them to be false, misleading or suspicious. Where Companies House suspects that there is evidence of fraudulent activity, the process of striking off companies will be expedited.

Companies will also now be required to submit annual confirmation that they have been formed for a lawful purpose and that their intended future activities are lawful – this change has now been incorporated into the CS01 form used for filing a company’s confirmation statement.

• To assist with the cleaning up process, Companies House now requires that each company provides a registered email address. This email address will not be made publicly available, but allows the Registrar to raise any queries they may have regarding a company. In addition, PO Box addresses will no longer be accepted as a company’s registered office address. Both of these changes have already been implemented and companies are now required to comply with them.

• Perhaps most significantly, the Registrar is aiming to introduce a new identity verification process by the end of March 2025. This will require anyone setting up, running, owning or controlling a company in the UK (such as directors and persons of significant control), and those who file on behalf of a company, to be verified before they can submit information to the Registrar.

This verification process will extend to third parties who file information on behalf of a company (known as ‘authorised third party agents’, or ACSPs), such as legal advisors and accountants. ACSPs will be required to confirm to the Registrar that they have appropriately verified the identity of their client before submitting information on their behalf.

Companies House are yet to confirm the form in which this verification process will take.

• Limits are to be imposed on the use of corporate directors (i.e. companies or corporate entities that act as a director of another company). This change was originally due to come into force in 2016 under the Small Business Enterprise and Employment Act 2015.

• The Registrar will seek to provide better protection in relation to personal information which is currently accessible on Companies House. This includes the suppression of a company's registered office address where this is a person's residential address.
• The Registrar, working with law enforcement and intelligence agencies, intends to tackle economic crime by developing a ‘strategic intelligence assessment’ to identify and assess strategic threats posed to the UK through the misuse of corporate structures. Once completed, Companies House will then issue a control strategy, together with a series of action plans, to detail how it and its partners will respond to any threats identified.

Overall, by implementing the changes above, Companies House intends to improve the quality and availability of information available to the public in relation to UK companies, which they consider will maximise the value of the Register to the UK economy. The 2024/2025 Plan also marks the end of the Registrar’s larger five-year strategy plan, which set out their approach for transformation.

If you require assistance or wish to discuss any of these changes, please contact a member of our Corporate team.

Emma Barclay, Partner: eba@bto.co.uk / 0141 221 8012

Erin Findlay, Trainee Solicitor: efi@bto.co.uk / 0141 221 8012