UK Economic Crime and Corporate Transparency (ECCT) Changes and Delivery in Entities

Background

On Monday, March 4, 2024, Companies House has released the first set of changes related to the UK Economic Crime and Corporate Transparency (ECCT) Act.

These changes impact several forms available for e-filing and paper format within Entities.

The changes were released to Entities on March 2, 2024.

Watch this video on the ECCT changes or continue reading.

ECCT changes: scope and impact on UK companies

The changes introduced as part of ECCT apply to new forms generated in Entities with Made Up Date (MUD) starting on the Companies House implementation date – March 4, 2024.

The changes apply also to Confirmation Statements with the Made Up Date starting from March 5, 2024.

Note

For forms generated with the Made Up Date prior to March 4, 2024, Entities still produce the form version prior to the ECCT changes.

Change summary

Form Description Changes

CS01

Confirmation Statement

  • Registered email address

  • Lawful purpose statement

  • Authenticating on behalf of company

IN01

Application to Register a Company (SBEE Act 2015)

  • Registered email address

  • Lawful purpose statement

  • Authenticating on behalf of company

AD01

Change of Registered Office Address

  • Authenticating on behalf of company

  • Appropriate registered office address

LLCS01

Confirmation Statement

  • Registered email address

  • Lawful purpose statement

  • Authenticating on behalf of LLP

LLIN01

Application for Incorporation of a Limited Liability Partnership (LLP) (SBEE Act 2015)

  • Registered email address

  • Authenticating on behalf of LLP

LLAD01

Change of Registered Office of a Limited Liability Partnership (LLP)

  • Authenticating on behalf of LLP

  • Appropriate registered office address

Legislative reference correction

We have been notified by Companies House that the new ECCT forms LLAD01 and LLCS01 provided by them and subsequently released to Entities on March 4, 2024, contain incorrect legislative references. Companies House have confirmed that they will accept the existing forms from Entities until they are replaced.

On April 8, 2024, the forms LLAD01 and LLCS01 have been replaced in Entities.

The following form corrections have been released:

Form Incorrect reference Correct reference released

LLAD01, page 3

In accordance with Section 87 of the Companies Act 2006 as applied by the Limited Liability Partnerships (Application of Companies Law) Regulations 2024.

In accordance with Section 87 of the Companies Act 2006 as applied by the Limited Liability Partnerships (Application of Companies Act 2006) Regulations 2009.

LLAD01, section 3

I confirm that the new registered office address is an appropriate address as outlined in section 2(5) of the Limited Partnerships Act 2000.

I confirm that the new registered office address is an appropriate address as outlined in section 2(5) of the Limited Liability Partnerships Act 2000.

LLCS01, page 3

In accordance with Section 853A of the Companies Act 2006. As applied to LLPs by The Limited Liability Partnerships (Application of Company Law) Regulations 2024.

In accordance with Section 853A of the Companies Act 2006. As applied to LLPs by The Limited Liability Partnerships (Application of Companies Act 2006) Regulations 2009.

LLCS01, page 6

In accordance with regulation 17ZB of The Limited Liability Partnerships (Application of Company Law) Regulations 2024.

In accordance with regulation 17ZB of The Limited Liability Partnerships (Application of Companies Act 2006) Regulations 2009.

Registered email address (REA)

This change affects forms:

  • CS01

  • LLCS01

  • IN01

  • LLIN01

As part of ECCT, companies are required to maintain an appropriate email address. An appropriate email address is one at which, in the ordinary course of events, emails sent to it by the registrar would be expected to come to the attention of a person acting on behalf of the company.

Providing the Registered Email Address for all UK companies and LLPs is mandatory under ECCT.

The Registered Email Address must be supplied on the first Confirmation Statement issued after the ECCT implementation. The Made Up Date for the statement must be a date after March 4, 2024.

You can register the same email address for more than one company.

Changes in Entities

You can record the Registered Email Address for UK companies and LLPs in Entities.

You can record REA in the following ways:

  • For one company at a time, by editing Company Details

  • For multiple UK entities, by using Batch Change Registered Email Address Wizard

To learn how to set the Registered Email Address for UK companies, refer to Set Registered Email Address for UK Companies.

Note

You can set REA for UK companies and LLPs before March 4, 2024.

When you add a Registered Email Address in Entities, the first Confirmation Statement you generate after the ECCT implementation date will include the REA. Incorporations will also include the REA entered.

Currently, to change the Registered Email Address after it has been submitted to Companies House, you will need to use the Companies House new online process for the EM01 form and then update the REA in Entities manually. The e-filing EM01 form will be added to Entities in a future release.

Lawful purpose statement

This change affects forms:

  • CS01

  • LLCS01

  • IN01

Under ECCT, there is a new mandatory requirement, to confirm that the intended future activities of the company/LLP are lawful, for the following:

  • Incorporating a new UK company

  • Submitting Confirmation Statements for a company

  • Submitting Confirmation Statements for an LLP

Changes in Entities

With the rollout of the changes to Entities, the lawful purpose statement will be a mandatory prompt in the Wizard process for the following actions:

  • Generating a Confirmation Statement for a company or an LLP

  • Incorporating a new UK company

Authenticating on behalf of company or LLP

This change affects forms:

  • CS01

  • LLCS01

  • IN1

  • LIN01

  • AD01

  • LLAD01

For selected forms, signatures are being replaced by authentication on behalf of the company.

Changes in Entities

When confirming selected events, the existing wizard for signing forms will now indicate who is authenticating the event on behalf of the company. The wizard will update the relevant new forms and e-filing submissions with the person's name. For other events, the field will still be used to indicate a signatory.

Appropriate registered office address

This change affects forms:

  • AD01

  • LLAD01

This change affects the following UK entities:

  • Companies – outlined in section 86(2) of the Companies Act 2006

  • LLPs – outlined in section 2(5) of the Limited Partnerships Act 2000

As part of ECCT, companies and LLPs are required to maintain an appropriate registered office address. An appropriate registered office address is an address where, in the ordinary course of events, a document addressed to the company, and delivered there by hand or by post, would be expected to come to the attention of a person acting on behalf of the company, and the delivery of documents is capable of being recorded by the obtaining of an acknowledgement of delivery.

Changes in Entities

Entities will not accept a PO box as Registered Office Address.

Entities will now prompt to confirm that the Registered Office Address meets the following criteria:

  • A document addressed to the company or LLP, and delivered there by hand or by post, would be expected to come to the attention of a person acting on behalf of the company or LLP, and

  • A person can get an acknowledgement of delivery to record the delivery of documents to the new registered office address.