This article provides general information only. It is not legal advice and does not create a solicitor-client relationship. Laws and interpretations change. Readers are encouraged to confirm details with current primary sources or a qualified solicitor.
The Economic Crime and Corporate Transparency Act 2023 received Royal Assent in October 2023. Implementation began in 2024. But in 2026, the rollout is still unfinished. Some reforms are already live and reshaping enforcement. Others have been pushed back. For directors, the question is no longer what is coming. It is whether you have kept up.
The Economic Crime and Corporate Transparency Act 2023 (ECCTA) is one of the most significant reforms to UK corporate regulation in decades. Its aim is to combat economic crime, increase transparency, and hold directors to a higher standard of accountability. It received Royal Assent on 26 October 2023.
But unlike a single piece of legislation that switches on overnight, the ECCTA is being implemented in phases. Some of those phases are already in force. Others have been delayed. And the enforcement landscape for director disqualification is shifting as each phase lands.
This article sets out what has already changed, what is still to come, and what directors should be doing right now.
Currently in Force
Companies House Powers (Live Since March 2024)
Since March 2024, Companies House has had the power to reject suspicious or incorrect filings, remove fraudulent data from the register, and share intelligence with law enforcement agencies. This was a fundamental shift. Companies House moved from being a passive filing cabinet to an active gatekeeper.
For ECCTA director disqualification enforcement, this matters enormously. Regulators can now identify patterns of misconduct across multiple companies and build stronger evidence before disqualification proceedings even begin. Companies House has already rejected thousands of suspicious filings and removed false data from the register.
Registered Office and Email Requirements (Live Since March 2024)
Every company must now have a physical UK address as its registered office. PO boxes are no longer accepted. Companies must also provide a registered email address. These changes tighten the net around shell companies and ghost directors who previously operated behind untraceable addresses.
Mandatory Identity Verification for Directors and PSCs (Live Since 18 November 2025)
This is the headline reform. Since 18 November 2025, all new directors and persons with significant control must verify their identity before their appointment can be registered at Companies House. Existing directors are within a twelve-month transition window, with individual deadlines linked to their annual confirmation statement filing dates. The backstop deadline is 17 November 2026.
Identity verification directly strengthens ECCTA director disqualification enforcement by closing one of the longest-standing loopholes in the system: banned directors re-entering the register under false or borrowed identities. It also makes it far easier for regulators to track individuals across multiple companies.
The Failure to Prevent Fraud Offence (Live Since 1 September 2025)
Large organisations now face criminal liability if they benefit from fraud committed by employees or associated persons, unless they had reasonable fraud prevention procedures in place. This offence came into force on 1 September 2025 under the Economic Crime and Corporate Transparency Act 2023 (Commencement No. 4) Regulations 2025. It is a live, enforceable offence, not a future reform.
While aimed at corporations rather than individual directors, it raises the bar on governance expectations and feeds directly into the standards regulators apply when assessing director conduct in disqualification proceedings.
Filing Fee Increases (Live Since 1 February 2026)
From 1 February 2026, Companies House filing fees increased under the Registrar of Companies (Fees) (Amendment) Regulations 2025. Digital incorporation rose from £50 to £100, and digital confirmation statements rose from £34 to £50. Paper filings also rose substantially. These increases are intended to help fund the expanded enforcement infrastructure the ECCTA requires.
What Has Been Delayed
Not everything is running to the original timetable. Several reforms initially scheduled for spring 2026 have been pushed back.
| Reform | Revised Timeline |
|---|---|
| Mandatory identity verification for presenters (those filing documents) | No earlier than November 2026 |
| ACSP registration for third party agents | No earlier than November 2026 |
| Registrar power to reject filings from disqualified directors | By end of 2026 |
| Changes to accounts filing (mandatory software filing) | Delayed indefinitely, under review |
The delays are partly practical. Companies House has said it needs time to manage the ongoing identity verification transition for directors and PSCs before layering on additional requirements. But the direction of travel has not changed. These reforms are coming. The question is when, not whether.
Still on the Horizon
Restrictions on Corporate Directors
The ECCTA will largely ban corporate directors. Where a corporate director is permitted, it must have a board made up entirely of natural persons whose identities have been verified. Overseas companies acting as corporate directors in the UK will be prohibited.
Status: timing still unclear. There is no confirmed implementation date, and the framework has not yet been brought into force. This is the only pending status for this reform. Treat any other timeline you see elsewhere as superseded.
For enforcement, this is significant. Once in force, regulators will be able to see who is actually running a company, making it far easier to pursue disqualification against the right individuals.
How This Changes ECCTA Director Disqualification Enforcement
The ECCTA does not rewrite the grounds for disqualification. Those remain the same. What it does is dramatically improve the infrastructure around detection and enforcement.
| Reform | Enforcement Effect |
|---|---|
| Identity verification (live) | Prevents banned directors re-entering under false identities |
| Companies House powers (live) | Enables earlier detection and stronger evidence building |
| Failure to prevent fraud offence (live) | Raises director oversight and governance standards |
| Corporate director restrictions (pending, timing unclear) | Will identify real decision makers behind companies |
| Presenter verification (delayed to late 2026) | Will close the filing loophole for unverified individuals |
Together, these reforms make it significantly harder for unfit directors to operate undetected. As each phase is implemented, the enforcement net tightens further.
What Directors Should Do Now
The message is straightforward. If you have not completed identity verification, do it now. Do not wait for your confirmation statement deadline. The process is a one-off and can be done through the GOV.UK One Login service or through an Authorised Corporate Service Provider.
Beyond identity verification, directors should be reviewing governance and compliance procedures, ensuring all company filings are accurate and up to date, and taking professional advice early if there is any doubt about conduct during a period of financial difficulty.
Companies House has confirmed that the identity verification transition period ends on 17 November 2026, and advisers tracking the rollout expect it to move from a supportive to an enforcement footing against unverified individuals once that transition period closes, in practical terms, from late 2026. Directors who are proactive now will be in a far stronger position than those scrambling at the deadline.
How we help
Regulators, claimants and boards are coming after individuals, not just companies. We protect directors when personal liability is at stake. For more information on how Essential Counsel supports directors, visit our Capabilities page or contact our team at Essential Counsel for a confidential discussion.