An introduction to Economic Crime and Corporate Transparency Act 2023 for charities: key changes from 18 November 2025

There are some key changes incoming in the Economic Crime and Corporate Transparency Act 2023 (ECCTA) which will affect many charities.

ECCTA, which originally received Royal Assent on 26 October 2023, is being brought into force in stages. This article summarises key changes with a particular focus on charities, and highlights points to be aware of before the next key implementation date of 18 November 2025.

The policy behind the changes

Firstly, it should be noted that ECCTA – a lengthy and detailed piece of legislation - was not introduced to target charities specifically. It was introduced by the government to prevent ‘organised criminals, kleptocrats and terrorists’ from using companies to abuse the UK’s ‘open economy’, to strengthen the response to economic crime, and support enterprise through the improvement of Companies House service and data. However, the broad scope of ECCTA is such that many charities are impacted by it.

The charities impacted by ECCTA

ECCTA affects companies regulated by the Companies Act 2006, including companies limited by guarantee and companies limited by shares.

This means that charitable companies and charities with trading subsidiaries will need to be particularly aware of the new requirements. They should have already started to receive notifications from Companies House alerting them to actions they will need to take, particularly around identity verification, referred to further below.

However, the ‘Failure to prevent fraud offence,’ which has been introduced by ECCTA and is also referred to further below, is relevant to all types of larger corporate charities, including CIOs and Royal Charter bodies.

Key changes so far

Since ECCTA received Royal Assent on 26 October 2023, some important changes have already been made:

• Since 4 March 2024 - Increase in Companies House powers: Companies House now has greater powers to improve the accuracy and quality of data on the Companies House register. In particular, Companies House can now:
  • exercise greater powers to annotate the register, to include helpful, additional information intended to provide improved insight – this can include notations indicating that a director or officer has not completed their ID verification;
  • refuse to accept and register a document which appears to be inconsistent with other information it holds;
  • require additional information to be provided, or require an inconsistency is resolved; and
  • remove material from the Register of Companies.
    
    These changes mean that Companies House has become a more active regulator in respect of company filings. Care must be taken to ensure that all information filed with Companies House is accurate and consistent or Companies House may well raise queries about it.
• Since 4 March 2024 - Registered email and office addresses: Every company must have an ‘appropriate’ registered email address and an ‘appropriate’ registered office address. An appropriate registered office is one where documents would be expected to come to the attention of a person acting on behalf of the company, and delivery can be acknowledged. An appropriate address would not include, for example, a PO Box number. The Registrar of Companies now has the power, where it believes that an address is not an appropriate address, to change the registered address to a default address nominated by the Registrar. It is important that a company responds swiftly to any notice from Companies House that its registered office has been changed. The company will have 14 days to either: give details of a new address; or, to object and provide evidence that its current address is appropriate.
• Since 8 April 2025 - Voluntary identity verification: It has been possible for directors and persons with significant control (PSCs) to verify their identity on a voluntarily basis before it becomes mandatory, as referred to below.
  
  In terms of how this is done practically, a director or PSC can verify their identity either using the ‘GOV.UK One Login’ ‘Verify you identity with Companies House’ service or, alternatively via an agent known as an authorised corporate services provider’ (ACSP). An ACSP will charge a fee for the service.  The online service requires specific types of ID to be provided and so where an individual cannot provide them it will be necessary to use an ACSP.  
• Since 1 September - A new offence of failure to prevent fraud:  ECCTA has introduced a new offence of failing to prevent fraud which applies to larger organisations. Please see our separate article here for more information on this. 

Key changes from 18 November 2025 – identity verification

From 18 November 2025, identity verification (via Companies House or an ACSP, as described above) will be mandatory for all new directors, members of LLPs and PSCs, as follows:

• Identity verification for new directors: From this date, it will become mandatory for any new director of a company to have their identity verified before being appointed.
  
  Under ECCTA, an individual must not act as a director and the company must ensure they do not act as a director, until their identity has been verified. ECCTA makes any contravention of these requirements a criminal offence.
  
  Bearing in mind the range of processes which charities have in place for appointing directors  (for example,  co-option by trustees; election at AGM by members; and/or appointment by another organisation), charitable companies will need to consider their particular processes and how and when they will ask candidates to verify their ID before they begin acting as directors.
  
  Charities will also need to take this into account when appointing directors to trading subsidiaries.
• Identity verification for new PSCs – It will also be mandatory for any individual who becomes a PSC on or after 18 November 2025 to verify their identity either before becoming a PSC, or within 14 days of Companies House being notified that they are a PSC.
  
  Not all charitable companies have a PSC due to the way they are structured, but for those which do, this requirement will need to be taken into account.
• Identity verification for existing directors and PSCs – For individuals who are already a director or a PSC on 18 November 2025, a twelve months transitional phase will begin during which time they will need to verify their identity:
  • Directors must verify their identity before their company’s next confirmation statement is filed after 18 November 2025. For example, if the company’s confirmation statement is due by 14 January 2026, all of the company’s directors must verify their identity in time for their verification code to be included in the confirmation statement ahead of the filing deadline.
  • PSCs who are also directors of the same company must notify Companies House of their personal code both in the company’s next confirmation statement in their capacity as director and within 14 days of the filing of the confirmation statement, in their capacity as PSCs. However, identity only requires verification once.
  • PSCs will need to verify their identity within the first 14 days of their birth month. For example, if a PSC’s date of birth is 15 December, they will need to verify their identity by 14 December 2025 (i.e. 14 days after 1 December).

In tandem with these changes, and also from 18 November 2025, companies will no longer be required to hold registers of directors, director's residential addresses, secretaries and PSCs. Instead, the information currently contained in the registers will need to be notified to and will be held centrally at Companies House. Please see our article here providing more detail on this. 

Practical steps which charities should take now

Charities should get ahead of these requirements and map out how their directors are currently appointed, and if they have any PSCs. They will need to determine when the current directors and PSCs will need to verify their identity and also decide how identity verification can be built into the process when there is a change of a directors or PSCs. 

It will normally make sense for existing directors and PSCs to verify their identity voluntarily now, rather than wait for the relevant deadline under the transitional period. 

Identity verification should not be left until a charity is nearing a filing deadline, as problems can arise – for example, if an individual expects to be able to use the online service but does not have one of the specific types of ID required, they will need time to find a suitable ACSP to assist. A recent change of address may also mean that identity cannot be verified using the online service.

Looking ahead

Further provisions of ECCTA are expected to come into force in Spring 2026, when it is anticipated that it will become necessary for any person filing a document at Companies House on behalf of a company to have their identity verified too. There is more information on this in this article here.

Later changes are also in the pipeline under ECCTA, including identity verification for corporate entities, and restrictions on the use of corporate directors. We will aim to keep you updated as implementation progresses.