Companies House identity checks: enforcement is no longer fit for purpose

Companies House identity checks: 17 November 2026 is the last day of the transition. Enforcement under the Companies Act 2006, the Economic Crime and Corporate Transparency Act 2023 and the Economic Crime (Transparency and Enforcement) Act 2022.

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Charles Pycraft · November 2026 · London

Cover card: Companies House identity checks. Navy ground with a gold-framed register of six rows, four ticked and two open, under a magnifying glass. Labelled ECCTA 2023, small CP mark. By Charles Pycraft

This article is part of Offshore: the enabler chain. It sits in pillar 2: Why the watchdogs miss it. Start with the series overview if you are new to the work.

Opinion. Updated on 13 November 2026.

The short version

Moneyland: not a country explains how identity checks work for directors and people with significant control (PSCs). This piece asks whether enforcement matches the scale of the register.

The statutory transition runs from 18 November 2025 through 17 November 2026. Some filing deadlines fall later. In my view, the published figures leave too much unanswered about overdue checks and the action taken.

Lenders, suppliers and the public rely on accurate company records.

What the law now requires

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) amended the Companies Act 2006 in four ways that matter here.

The Economic Crime (Transparency and Enforcement) Act 2022 covers overseas entities holding qualifying UK land. Section 7 requires registered entities to file within 14 days of the end of each update period, normally 12 months. SI 2023/696 governs civil penalties.

Identity check compliance figures

Companies House publishes quarterly management information on compliant appointments. The July to September 2026 release, published on 29 October 2026, shows the position at 30 September 2026:

These count appointments, not people, and are unaudited. On my arithmetic from the published percentages, roughly 1.9 million director appointments and roughly 2.1 million PSC appointments were not yet compliant at 30 September 2026, seven weeks before the end of the transitional period. Some were not yet due. The release does not say how many were overdue.

On 18 June 2026, Spotlight on Corruption reported that a Freedom of Information response put non-compliance letters at 983,000 between November 2025 and May 2026 and put 183,000 "controlling shareholders" in default as of May. The government's June progress report separately recorded more than three quarters of a million default letters.

Companies House enforcement so far

The Companies House annual report and accounts 2025 to 2026 records activity against a register of 5.48 million companies at 31 March 2026, with 815,280 incorporations in the year:

One case shows the scale a single gap can reach. Under Operation Hammerhead, Insolvency Service investigations informed by Companies House intelligence led the High Court to wind up three connected companies on 29 January 2026. Investigators found more than 11,000 companies had been registered through them without proper checks, many with no real UK presence.

The penalty figures are smaller. The 2025-26 trust statement records 703 penalties for failure to deliver a confirmation statement, totalling £176,000, or about £250 each. It gives no separate total for identity-check penalties. Its published scale runs from £250 for a first minor offence to £2,000 for a fourth or later very serious offence, a fifth of the statutory cap. On the Register of Overseas Entities, which held 33,100 entities at 31 March 2026, one penalty was levied in the year and 19 were reversed, after what the report calls "a short operational pause in 2024 to 2025".

The Insolvency Service secured its first convictions for identity-check offences on 16 September 2026. The Insolvency Service announced that three directors of two companies were fined between £80 and £307 at City of London Magistrates' Court, plus costs and victim surcharges. Two acted before completing their own checks. The third failed to take reasonable steps to prevent a co-director from doing so. Each was also convicted of a late confirmation statement offence. The press release says they had multiple opportunities to comply.

Companies House's approach to non-compliance, updated 5 December 2025, lists prosecution, Insolvency Service referral, penalties, annotation and strike-off. It treats three or more offences in five years as a guide to a serious case. The policy gives no volume target for individual sanctions.

ACSPs: the agent layer

Authorised corporate service providers (ACSPs), registered from 18 March 2025, can complete checks for clients. Applicants must carry on relevant business in the UK and have a UK anti-money laundering supervisor under the Money Laundering Regulations 2017 (section 1098B). By 31 March 2026, 783,000 checks had been completed through ACSPs, against 3 million through GOV.UK One Login.

The registrar can suspend or remove an ACSP and must tell its supervisor when it does (regulations 17 and 18 of SI 2025/50). The 11 November 2026 file on Companies House's ceased or suspended list has 693 entries: 494 ceased and 199 suspended. It lists HMRC for 284 entries. Most others list a professional body. Cessation includes voluntary exits, and the file gives no individual reasons. The public list of active ACSPs covers only those that chose to be published.

The Money Laundering Regulations allow information sharing with the registrar in specified circumstances (regulation 52). I found no routine duty for a supervisor to report what it did after a suspension or cessation notice. Professional-body AML supervision is no longer fit for purpose covers the wider supervision regime.

Checks for people who file on behalf of companies are not yet in force. The ECCTA outline transition plan records that on 5 August 2026 their due date was moved to no earlier than November 2027. It sets no date for corporate director restrictions, and puts limited partnership reforms at no earlier than the end of 2026.

The money

Operating expenditure reached £256.1 million in 2025-26. Department funding of £15.2 million paid for enforcement activity where a penalty or sanction is levied. Section 1063 allows certain Insolvency Service costs to be reflected in Companies House fees. The report records £63.8 million of 2023 Act work, up from £52.1 million. Amounts recovered under section 1132A go to the Consolidated Fund. The report gives no breakdown linking identity-check spending to its outcomes.

Why this reading says "no longer fit for purpose"

The 2026-27 business plan targets at least 225,000 actions against register abuse. It also says that by the end of the financial year every company will have met the identity requirements tied to its confirmation statement, or be on a pathway to compliance or enforcement action. In my view, those targets need quarterly figures showing how many appointments are overdue and what action followed. That is the test after the transition.

What should change

  1. Publish defaults, not only compliance. Publish quarterly counts of overdue appointments, letters, penalties and their value, prosecutions, annotations, strike-offs and ACSP suspensions. Break figures down by register where applicable. Publish annual targets for identity-check enforcement. Owner: Companies House and the Department for Business, Innovation, Science and Trade (BIST), through the public measures statement.
  2. Annotate, then act. Use annotations where authorised, reject incomplete confirmation statements and refer suitable cases for enforcement. Treat persistent non-filing as a reason to inquire. Use section 1000 where there is reasonable cause to believe the company has stopped trading or operating. BIST should consult on legislation for any new automatic consequence. Owner: Companies House, BIST.
  3. Use the full penalty range. Revise the penalty scale to allow higher penalties for serious, continuing or repeat offences, within the applicable legal limits and where proportionate. Publish quarterly outcomes. Owner: Companies House, BIST.
  4. Close the ACSP loop. Require AML supervisors to report back on suspension or cessation notices. Companies House should review agents' identity checks with relevant supervisors and publish aggregate reasons by category. Owners: HM Treasury for supervisor reporting, Companies House for identity checks, and BIST for any additional duties on agents under section 1098G.
  5. Cross-check the registers. Pilot matching across overseas entity records, the Trust Registration Service and PSC filings where lawful. Publish aggregate results for comparable records. Owners: Companies House and HMRC, with BIST and HM Treasury if new powers are needed.
  6. Tie fees to output. Publish how much fee income funds identity-check enforcement and what it produces, alongside Insolvency Service referral outcomes. Owner: BIST, Companies House, Insolvency Service.
  7. Fix the remaining dates. Set a firm date for checks on people who file on companies' behalf, and a timetable for corporate directors and limited partnerships. Owner: BIST, through commencement and implementing regulations where needed.

A note on records

I work on business development and communications for Partisan, which offers file fingerprint receipts for comparing copies. ACSPs must keep the records specified in regulation 15 of SI 2025/50 for seven years.

About this piece

Public sources only, as linked. It makes no allegations about any person or firm, and the concluded prosecutions are cited only for the scale of sanction. Holding money offshore is not itself unlawful. Opinion is marked as argued reading. This piece is for general information and is not legal advice.

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Related: Moneyland: not a country; Professional-body AML supervision is no longer fit for purpose

Series overview: Offshore: the enabler chain

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