Published: 17 January 2024 4:59 pm  Author: Oliver Stanley

Economic Crime and Corporate Transparency Act 2023 – first implementation plans

The new Economic Crime and Corporate Transparency Act 2023 (ECCTA) received royal assent in October 2023.  Companies House (and Kudocs) are getting ready for implementation of the various changes.  These will be done in stages over the coming months and years, as secondary legislation is needed in many cases to bring the changes into effect.

We now know from Companies House what these first changes will be – which are due to go live in March 2024.

1. Each entity will be required to provide a registered email address to Companies House as part of their core information.
   1. For new entities this will need to be provided as part of the incorporation application.
   2. For existing entities an email address will need to be included in the first confirmation statement filed after implementation.  Thereafter, entities will not need to include the email address in confirmation statements, but there will be a new standalone process built for entities to change their registered email address (a bit like adding/updating SAIL details – there is no legal process, it is just a Companies House update).
2. Each company will be required to confirm that their registered address is an “appropriate address”.
   1. This will be required only as part of an application to change registered address.
3. Each company will be required to confirm that they are carrying out a “lawful purpose” in their business activities.
   1. For new entities this will need to be provided as part of the incorporation application.
   2. For existing entities this will need to be included in every confirmation statement filed after implementation (ie confirmed on at least an annual basis).
4. PO Box addresses will not be permitted as registered office addresses – either at incorporation or in applications to change registered address.

Kudocs is fully aware of these changes and the technical changes needed to the system to support them.  Kudocs will be ready for the implementation date. Our customers will not notice anything different when the time comes and we’ll provide full explanations and support – as always – as soon as the changes are ready and live.

The big question on everyone’s mind is regarding the requirement for identity verification of certain stakeholders – what will be required to ID verify, who will be able to do that, and how this relates to existing verification being carried out by professional advisers (KYC/ AML checks, etc).  We are in close contact with Companies House about this and will provide updates as & when this becomes clearer.  It is likely not to come into effect for at least 1 year.