Annual company filings: what’s new with the Economic Crime and Corporate Transparency Act 2023?

Confirmation statements

Registered email address

The first change that was made to the confirmation statements was the requirement to confirm a registered email address from 5 March 2024.

The email address is not published on the public register, but it is used by Companies House for communication about the company to which it relates. For this reason, it is important that companies use an appropriate email address which is regularly monitored.

There is a duty on companies to maintain the registered email address the same as they would their registered office address.

A registered email address can be changed using the online ‘update a registered email address’ service at Companies House.

Statement to confirm lawful purpose

Our recent article on the “ECCTA, incorporations and Statutory Registers” explained that subscribers incorporating a new company need to confirm that they are forming the company for lawful purposes.

This is an ongoing obligation under the ECCTA. As of 5 March 2025, companies now need to confirm every year, when filing the confirmation statement, that all intended future activities will be lawful.

As with the incorporation form, this statement is included on the confirmation statement (CS01) and is to make it clear that all companies on the register, new and existing, have a duty to operate in a lawful way.

Companies House may take action against a company if they receive information that confirms it is not operating lawfully. Furthermore, CS01s without the lawful statement ticked will not be accepted Companies House for filing.

Director UI codes

18 November 2025 marked the beginning of the year-long transition period whereby companies are required to confirm their directors’ unique identifier (UI) codes on the confirmation statement. UI codes are also referred to as IDV or an Identity Verification codes.

UI codes for directors and persons with significant control (“PSCs”) are obtained by completing identity verification checks with Companies House. Our article the “ECCTA 2023 and verifying your identity”, introduced the process and we will be posting a follow up article with further information on this in due course.

It should be noted that from 18 November 2025, a company is unable to file their confirmation statement unless the UI codes have been provided for all directors appointed at Companies House within the relevant period.

November 2026 marks the end of the transitional period. All directors and PSCs should have their codes by this point and have informed Companies House via the confirmation statement process.

Shareholder information

In an effort to make company ownership more transparent, Companies House has advised that companies will be required to provide a one-off, full list of shareholders in their confirmation statement.

An estimated date of implementation for this is currently unknown, but we understand it will be accompanied by the requirement for the full names of shareholders to be recorded in the register of members.

Companies House enforcement action

Like many other filings, the CS01 has a 14-day filing window. For example, if a company’s confirmation statement is due on 1 April 2026, the CS01 must be filed with Companies House by 14 April 2026.

If, for any reason, a company is unable to file the confirmation statement and this remains overdue after Companies House has sent their reminder letters, the Registrar can file a First Gazette notice for compulsory strike-off.

From the notice publication date, a company then has two months to file the confirmation statement or make a representation to Companies House. If neither step has been taken, the company will be struck off the register and dissolved.

If the reason a confirmation statement cannot be filed is because a director or PSC is unable to complete their identity verification statement, it is possible to notify Companies House of this in order to avoid or delay strike off action. Once the company is in receipt of the first reminder to file the overdue confirmation statement from Companies House, it must apply to Companies House within 28 days of the date of such letter. Companies House judges each representation on its own merit and Companies House will write to the company to let them know if the representation has been successful. The Registrar’s decision is final.

If we file your confirmation statement for you, we can make this representation on your behalf.

Annual accounts

Filing online

The online filing services for annual accounts and company tax returns is closing on 31 March 2026.

From 1 April 2026, companies and service providers will need to use commercial software to file the annual accounts and company tax returns with HMRC.

Companies House has explained this is because the online filing service does not meet modern digital standards or recent changes to UK company law.

Filing paper copies

Companies House had previously indicated that companies will no longer be able to file their accounts in paper copy from April 2027, from which point all accounts will need to be filed using commercial software.

These reforms will now not be introduced in April 2027 and are still under review. Companies House has indicated that an update will be provided shortly but that companies will receive at least 21 months’ notice to prepare.