The Companies House reform programme continues to develop, with further changes being implemented following the introduction of mandatory identity verification in November 2025. This article covers the latest developments since our November 2025 piece, “Companies House reforms: what you need to know about compliance and enforcement”
The developments increase the compliance burden on companies and their officers and, signal a more active and enforcement-led approach by Companies House.
Companies House will no longer operate as a passive registry. Instead, it is becoming an active gatekeeper of corporate information, with greater scrutiny of filings and those responsible for them. In practical terms, this creates greater likelihood of rejected filings where requirements are not met, timing pressure and operational difficulty, combined with greater governance expectations.
Some companies are encountering delays correcting historical discrepancies in Companies House records (for example, incorrect dates of birth). These issues can affect the ability to meet confirmation statement deadlines, particularly where identity verification codes must be included for the first time.
While Companies House provides a process for making representations in cases of non-compliance, this should not be relied upon as a substitute for timely compliance.
Companies House fees increased with effect from 1 February 2026, reflecting its expanded role and enhanced enforcement powers. The increase form part of a broader shift towards a more resourced and proactive regulator.
ECCTA introduces reforms to statutory registers to increase transparency, consistency and accuracy of public data. This includes the abolition of certain registers and increased centralisation of information at Companies House. However, companies will continue to have ongoing obligations to maintain accurate internal records and ensure that information filed centrally is correct and up to date.
The previous ability to elect to hold certain registers at Companies House is being removed, placing greater emphasis on the accuracy of filings, as Companies House will increasingly become the primary public record.
A recent High Court decision, Palmer v P1 Pit Stop Limited [2026] EWHC 1924 (Ch), serves as a timely reminder that, notwithstanding these centralisation reforms, companies must still maintain their own register of members. In that case, the court ordered the rectification of a company’s register of members under section 125 of the Companies Act 2006, confirming that the court’s statutory power extends to creating a register from scratch where a company has never maintained one.
Companies House confirms it will introduce corporate director reforms at “a later date” — separate from the 18 November 2025 rollout. These corporate director reforms will require:
Companies House continues its transition towards software-only filing of accounts, with implementation currently expected from April 2028. This development will require organisations to review their internal systems and processes in advance, particularly where filings are currently managed manually or through legacy processes.
While companies will continue to be able to file directly, any third-party intermediary submitting filings or carrying out identity verification on behalf of clients will need to be appropriately authorised as Authorised Corporate Service Providers (ACSPs) by no earlier than November 2027. Identity verification of presenters will also become a compulsory part of filing any document from the same date. Companies House has confirmed that it will give at least 6 months’ notice before these requirements come into effect.
This represents a significant change for organisations that rely on external advisers and will require early planning to ensure continuity of filing processes.
Greenwoods Legal Services Limited is a registered Authorised Corporate Service Provider (ACSP), authorised to submit filings and carry out identity verification on behalf of clients. For more information, see: https://www.greenwoods.co.uk/expertise/corporate commercial/identity-verification-authorised-corporate-service-provider-acsp/ .
Directors are being warned to verify their identities with Companies House or risk prosecution, after the Insolvency Service secured its first convictions for identity verification offenses. Any director or person with significant control (PSC) who has not verified should do so within the timeframe that applies to their company.
Directors should also confirm that every co-director has verified, because failing to stop an unverified director from acting can lead to prosecution. To avoid enforcement a default letter should be dealt with immediately.
Companies House reform programme is not only ongoing but increasingly focused on active oversight, data integrity and enforcement.
Organisations should use the current transition period to:
A proactive approach now will help mitigate disruption and reduce compliance risk as the regime continues to evolve.
Greenwoods supports organisations in navigating Companies House reforms, including identity verification, filings and ongoing compliance obligations.
If you would like to discuss how these changes affect your organisation, please get in touch via email at [email protected] or call +44 (0)20 7504 1151
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