ECCTA for Charities: Maintaining Registers

Introduction

This article forms part of our series of updates looking at the Economic Crime and Corporate Transparency Act 2023 (ECCTA) and its impact on charities. 
Many of the changes brought in by ECCTA will increase compliance requirements for charities, and will affect how their company information is managed, administered and verified.

In this article, the focus is on the changes being brought in this autumn and in Spring 2026 in relation to the registers that must be maintained by charities caught by the Act.

The current position 

Currently, companies are required to keep a number of statutory registers:

• Register of directors
• Register of directors’ residential addresses
• Register of secretaries (even if a company chooses not to appoint a secretary)
• Register of persons of significant control (PSCs)
• Register of members

The Companies Act 2006 requires companies to keep these registers at their registered office or at a single alternative inspection location (SAIL), and to make registers available for inspection by any member of the company without charge, or otherwise for a fee. The register of residential addresses is not open to public inspection or to the members.

If a company’s statutory registers are not properly maintained, both the company itself and the officers of a company (i.e. the directors/trustees and the secretary) commit an offence.

Changes under ECCTA from 18 November 2025 

Registers of Directors, Directors’ Residential Addresses, Secretaries, and PSCs

From 18 November 2025, the obligation to maintain the first four registers listed above will be replaced by a requirement to file certain information at Companies House.

This means that registers of directors, their residential addresses, secretaries, and PSCs will be kept centrally by Companies House, instead of locally by the company. The Companies House record will become the authoritative source of information.

Any changes to these registers must be updated by a notification to the Registrar within 14 days of the change being made.

Directors’ residential addresses and day (but not month or year) of birth will be considered “protected information” not available to the public.  This is in addition to measures already in force whereby individuals (including members) may now apply to the Registrar to protect their personal information on the Companies House register. These measures extend the existing residential address protection regime and introduce protection in respect of signatures, business occupations and day of birth.  They aim to prevent misuse of data—such as fraud, identity theft, or risks arising in contexts like domestic abuse— while preserving accountability and transparency about who runs companies. 

Registers of Members 

In contrast, the rules regarding maintenance of a register of members is reversed.  
Previously, private companies have had the option to elect to hold their register of members centrally at Companies House (although many charities will not have elected to use this facility). From 18 November, this option is being removed, and instead companies will only be able to maintain their own register of members internally.

Changes from late 2026 

The changes are supplemented by further requirements intended to improve the quality of information contained within the registers, which will be in force from late 2026 (exact date to be confirmed).

‘Required information’ for directors

A company must also notify Companies House of the "required information" in relation to its directors. This includes:

• Name;
• Date of birth and nationality;
• Service addresses;
• Usual residential address; and
• Country of residence.

‘Required information’ for members

In addition to existing requirements, the information collected for the register of members will be standardised, and must contain the following “required information”:

• in the case of an individual member, the individual member’s forename and surname (with no initials);
• in the case of a company, the full name of the company; and
• for all members, a service address.

Members will be under a new duty (i) to provide this required information within two months of becoming a member, and (ii) to give notice of relevant changes to their required information to companies of which they are members within two months of such changes occurring. Companies will also have new powers to require members (and former members) to provide this required information where they fail to do so.

Private companies will also be required to retain historical members’ information, and to record the dates on which changes to required information are made, until ten years after the date on which a member ceases to be a member (unless a court orders otherwise). 

New offences

ECCTA amends the Companies Act 2006 to create several new offences in relation to the provision of information for the central register. Further legislation is required to implement these new offences.

Once in force, a member that fails to provide information for the register of members, or who provides information that is misleading, false or deceptive, will be committing an offence.

Practical steps

Trustees of charities affected by the forthcoming changes should view ECCTA as a catalyst rather than a burden: the changes provide a good opportunity to review their internal registers and ensure that the charity’s records are in order.

Trustees should prepare for the tightening regulatory environment by:

• Checking their registers of directors, directors’ residential addresses, secretaries, and PSCs to see that the information is (i) up to date, and (ii) readily available, and making sure Companies House holds the relevant information. 
• Checking their register of members to ensure that the information is (i) up to date, (ii) in a format that can accommodate the additional required information that companies will now need to keep, and (ii) held at the company’s registered address or SAIL address as applicable.
• Checking the Companies House website and look out for any updates from Companies House made via email, for new information on the practical requirements. 
• Identify any sensitive information that should be protected from public disclosure.
• Consider introducing new internal policies for when director, secretary, PSC, or member information changes so that this information can be updated internally / at Companies House within the stipulated periods.