Four draft statutory instruments (SIs) were brought before Parliament on 3 July to allow the legal mechanisms necessary to enforce several provisions of the Economic Crime and Corporate Transparency Act 2023 (ECCTA). 

These SIs represent a significant step forward in the implementation of the ECCTA. They provide the regulatory framework required to give practical effect to many of the Act’s provisions, including identity verification of directors and persons with significant control (PSCs), the use of authorised corporate service providers (ACSPs) and the replacement of local statutory registers with centralised reporting at Companies House.

They include identity verification requirements, the abolition of certain local registers and the expansion of transparency obligations to a broader range of entities. 

The draft instruments must be approved by both Houses of Parliament before they can come into force. They are designed to come into effect in line with various sections of ECCTA through subsequent commencement orders. 

SI one: Consequential, Incidental and Miscellaneous Provisions

The Economic Crime and Corporate Transparency Act 2023 (Consequential, Incidental and Miscellaneous Provisions) Regulations 2025 makes amendments to various primary and secondary legislation to reflect changes introduced by ECCTA. 

Critically, it includes the removal of the statutory requirement for companies to maintain local registers of directors, secretaries and PSCs. Companies will instead be required to keep this information up to date through filings at Companies House once the regulations are in place.

In addition, the regulation introduces a requirement for ACSPs to include their anti-money laundering (AML) supervision registration number when filing on behalf of clients. This change will apply when the director identity verification requirements in section 43 of ECCTA are brought into force. 

ICAEW has raised concerns that the requirements relating to ID verification are more rigorous than those in the risk-based approach required under the AML regulations. As such, members should not assume that compliance with the AML regulations ensures compliance with the standards of ID verification as outlined in this legislation. 

The instrument also includes savings and transitional provisions to support implementation, including time limits for companies to notify Companies House of information previously kept in local registers.

SI two: Authorisation to Register, Unregistered Companies and Overseas Companies

The Companies (Authorised to Register), Unregistered Companies and Overseas Companies (Application of Company Law) Regulations 2025 applies certain ECCTA provisions to companies that do not fall within the standard framework of the Companies Act 2006, including companies authorised to register, unregistered companies and overseas companies with a UK presence.

Once the relevant provisions of the Companies Act are in force, the officers and PSCs of these entities will be required to undergo identity verification and meet the same obligations as those of UK-incorporated companies. 

The regulation also provides for enforcement, including criminal offences for failure to comply with the new requirements. Transitional arrangements are included to allow existing directors and PSCs of these companies to comply with identity verification within a specified period after commencement.

SI three: Application to Limited Liability Partnerships

The Limited Liability Partnerships (Application and Modification of Company Law) Regulations 2025, adapts the ECCTA framework for use by limited liability partnerships (LLPs). 

It applies company law provisions relating to identity verification, the abolition of local registers, and PSC disclosure to LLPs, with modifications to reflect their governance structure. 

Under this regulation, LLPs will no longer be required to maintain internal registers of members or PSCs. Instead, they must provide this information to Companies House and update it as required. 

Members will also be subject to the identity verification process under this SI. The regulation includes transitional provisions giving LLPs 14 days from commencement to notify Companies House of relevant information that was previously recorded in local registers. New offences and enforcement mechanisms are included in line with those applying to companies.

SI four: Amendment of the PSC Register Regime

The Register of People with Significant Control (Amendment) Regulations 2025 amends the existing PSC regime to reflect changes introduced by ECCTA. In particular, it addresses the move away from company-maintained PSC registers to a fully centralised public register at Companies House. 

The regulation requires companies to report all relevant PSC information, including investigation dates and changes in control, directly to Companies House within prescribed time limits. 

The previous duty to keep a local PSC register will cease to apply. Notably, the regulation grants Companies House the power to correct certain inaccuracies or omissions in the PSC register, in line with its expanded role under ECCTA. This power will come into force alongside the commencement of section 790LA of the Companies Act 2006, inserted by ECCTA.

Implementation and next steps

These measures are subject to Parliamentary approval and, providing approval is received, the regulations will come into force in accordance with future commencement orders that will bring the relevant provisions of the ECCTA into effect. Anticipate future SIs to address other provisions within the act.

Companies, LLPs, ACSPs and other affected entities will need to prepare for the transition to the new framework, including changes to filing obligations and identity verification procedures. ICAEW will continue to update members on the progress of the approval of these SIs through the Parliamentary process, as well as highlight forthcoming government guidance.