ECCTA for charities: Filing documents at Companies House

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. The focus of this short instalment (the fourth in the series) is on upcoming requirements for those making filings on behalf of a company.

Changes expected in Spring 2026 - identity verification for those filing documents
In addition to the identity verification requirements for directors and persons with significant control (PSCs) (referred to in our article here), it is anticipated that from Spring 2026 it will become necessary for persons filing information at Companies House on behalf of a company to have their identity verified. Companies will broadly have two options each time they file:

• To have an individual (such as a director or secretary or other person) who has verified their identity to make the filing on behalf of the company; or
• To instruct an authorised corporate service provider (ACSP) to make a filing on their behalf. An ACSP is an entity which has been registered with Companies House as an ACSP under ECCTA. ACSPs include law firms, accountants and company service providers that are supervised for anti-money laundering purposes. 

Checking documents before filing 
Under ECCTA, Companies House also already has additional powers (amongst others) to query and reject information that appears incorrect or inconsistent. This means that it has become practically more important for companies to ensure that the information they are filing at Companies House is correct.  

Practical steps to take now
To stay ahead, charities caught by ECCTA should map the filings they make routinely with Companies House (eg annual accounts) as well as ad hoc filings (eg changes to the directors or to the articles), and how they are currently made, both for the charity and (if applicable) any subsidiaries.

Charities should then consider what will be required to ensure they meet the new requirements from next spring. For example, if a charity has a company secretary who already handles the charity’s filings, it will be a matter of ensuring that they verify their identity ahead of any deadline. For a charity without a company secretary, it may be appropriate to allocate responsibility for certain filings to a particular director (whose ID will have been verified as a director). The solution will depend on the charity’s circumstances but should be considered in advance to ensure filings are not delayed when they need to be made.