Companies House has been reforming in continuous waves since March 2024 under the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023), with a parallel Register of Overseas Entities regime predating it from August 2022 under the Economic Crime (Transparency and Enforcement) Act 2022 (ECTEA 2022). Eight operative reforms have landed in sequence so far, a ninth (Limited Partnership reforms under ECCTA Part 2) is in phased rollout, and a tenth (a later-phase ID verification extension to filers and corporate-officer scenarios) is expected no earlier than November 2026.

This page sequences each reform by its in-force date, anchors each one to the operative statute, and sets out what it means for a typical landlord LtdCo portfolio. The format is taxonomic and chronological; for the operational walkthrough of any individual reform, follow the forward-link out to the deep-dive page. The role of this page is the master index, not the deep dive.

The Inventory in Date Order

In-force dateStatutory anchorWhat it doesLandlord-LtdCo implication
1 August 2022ECTEA 2022 c. 10Register of Overseas Entities: overseas entities owning UK property must register and disclose beneficial owners annuallyRelevant where any portfolio vehicle is an overseas entity (Jersey, BVI, Isle of Man) or where a deal counterparty is one
1 March 2024ECCTA Part 3 plus Sch 2 commencementECTEA 2022 amendments via ECCTA Part 3 in forceTightens the Register of Overseas Entities updating and sanctioning regime
4 March 2024ECCTA ss.28-30 (Companies Act 2006 inserted-s.88A and following)Registered email address required, appropriate-address rule for registered office, confirmation statement fee increase to £50 online or £110 paperEvery SPV needs a registered email, must reroute PO-box-only registered offices, and pays the higher confirmation statement fee
5 March 2024ECCTA ss.59-63Lawful purposes statement added to confirmation statement (annual positive declaration)Annual tick-box at the confirmation statement and an evidentiary artefact if a future false-statement proceeding arises
8 April 2025Commencement Regulations under ECCTA 2023Identity verification opens voluntarily for directors and PSCsOptional early-mover for portfolios wanting a clean post-March-2024 file
18 November 2025ECCTA ss.40-45 plus s.64, s.65, s.68Identity verification becomes a legal requirement for newly appointed directors and PSCs; twelve-month transition window opens for existing rolesEvery natural person across the portfolio needs a Companies House personal code by the next confirmation statement within the window
Around November 2026Transition window closeExisting directors and PSCs final deadlineOperational deadline for full portfolio identity-verification coverage
No earlier than November 2026Later-phase Commencement RegulationsSeparate later phase for people who file at Companies House plus corporate-officer scenariosMostly relevant to filing agents and corporate directors; natural-person SPV directors are already covered
Phased rolloutECCTA Part 2 (Limited Partnerships)LPs under the Limited Partnerships Act 1907 brought into a Companies-Act-2006-style regimeRelevant to property-fund LPs, JV-development LPs, and family-investment LPs holding tenanted property

The reforms operate in parallel. A typical landlord LtdCo portfolio is touched by most of them: every UK-incorporated SPV is affected by the 4 March 2024 changes, the 5 March 2024 lawful purposes statement, and the 18 November 2025 identity verification regime. The Register of Overseas Entities and the Limited Partnership reforms come into play only for portfolios that use the relevant vehicles, but those vehicles are common enough across the wider property landscape that the umbrella matters.

1 August 2022: The Register of Overseas Entities

The Register of Overseas Entities (RoE) is the oldest of the current Companies House reforms and the one most often misattributed to ECCTA 2023. It was created by the Economic Crime (Transparency and Enforcement) Act 2022 (ECTEA 2022), in force from 1 August 2022, in response to the post-Russian-sanctions policy push to expose beneficial ownership of UK property held through overseas entities.

Any overseas entity that owns, or buys, or disposes of UK property must register at Companies House and disclose its registrable beneficial owners. The annual updating statement is due within 14 days of the end of each update period (ECTEA 2022 s.7), not within 14 days of the registration anniversary. The distinction matters because the update period is defined separately and is not always aligned with the calendar year. Failure to comply is a criminal offence under ECTEA 2022 s.8; removal from the register is a separate matter under s.9. The most operationally significant consequence is the HMLR disposition-block under Land Registration Act 2002 Sch 4A (inserted by ECTEA Sch 3): a non-compliant overseas entity cannot lawfully dispose of registered UK land while the non-compliance subsists.

ECCTA 2023 Part 3 amended ECTEA 2022 in several places (in force from 1 March 2024 per ECCTA Sch 2 commencement), tightening the updating duty and adding the compulsory-registration-notice power under ECTEA s.34. The RoE primary statute remains ECTEA 2022; ECCTA is the amending statute.

For most UK-incorporated landlord SPVs, RoE is not directly applicable. It becomes relevant where any portfolio vehicle is an overseas entity (a Jersey, BVI, or Isle of Man holding company over UK land is the common shape), or where the SPV deals with an overseas-entity counterparty whose RoE status affects the SPV's title position.

4 March 2024: Registered Email, Appropriate Address, and the Fee Increase

The 4 March 2024 commencement bundled three operational changes under ECCTA ss.28-30 and the Companies (Registration etc) Regulations 2024.

First, registered email address: every UK company must have a registered email address, used by Companies House for statutory communications. The email is not published on the public register; it is a private Companies House-to-company channel. New companies provide the registered email at incorporation. Existing companies provide it at the next confirmation statement filed on or after 4 March 2024.

Second, appropriate address: the registered office must be capable of acknowledging service of documents delivered to the address, and the company must be able to demonstrate, on request, that mail addressed to the registered office is reaching it. PO-box-only addresses (where there is no physical premises or staff that can sign for service of documents) generally do not qualify. Common operational fixes include using the accountant's office, a staffed virtual-office provider, or the director's residential address.

Third, the confirmation statement fee was increased to £50 online or £110 paper, alongside increases to other Companies House filing fees.

For a five-SPV landlord portfolio the immediate operational task is to confirm a working registered email for each SPV, audit each registered office against the appropriate-address test, and budget for the higher confirmation statement fee at each next filing.

5 March 2024: The Lawful Purposes Statement

Under ECCTA ss.59-63, every confirmation statement filed on or after 5 March 2024 must include a lawful purposes statement: a positive declaration that the company's intended future activities will be lawful. The declaration is annual (it is re-stated on every confirmation statement), not a one-off statement at incorporation.

The statement does not require evidentiary substantiation at the moment of filing. The director or officer who signs it is, however, exposed to false-statement proceedings if the declaration is materially untrue (for example, where the company is being used as a vehicle for fraud or money-laundering, and the directors knew or should have known). The statement is short, but it is not an empty formality; it changes the evidentiary baseline for downstream enforcement.

For a landlord LtdCo, the lawful purposes statement is a tick-box at the annual confirmation statement. The operationally interesting feature is that it consolidates with the other 4 and 5 March 2024 changes (registered email, appropriate address, fee increase) into a single annual touch-point that the company secretarial workflow handles in one pass.

8 April 2025 and 18 November 2025: Identity Verification

The identity-verification regime is the most operationally significant of the current reforms and the one that affects every UK company director and PSC. Voluntary verification opened on 8 April 2025. From 18 November 2025, identity verification became a legal requirement for newly appointed directors and persons with significant control under ECCTA ss.40-45 plus s.64 (PSC verification), s.65 (procedure), and s.68 (allocation of unique identifiers, the personal code).

The same date opened a twelve-month transition window for existing directors and PSCs in office on 17 November 2025: each company must carry verified personal codes for every in-scope individual on its next confirmation statement filed within the window, which ends around November 2026.

Verification is per natural person, not per company. One verification (via GOV.UK One Login, free and self-service, or via an Authorised Corporate Service Provider under ECCTA s.66) produces one Companies House personal code under ECCTA s.68 that covers every directorship and PSC role the natural person holds across every UK company.

For a multi-SPV landlord portfolio, this is the single most operationally useful fact about the new regime: a director of five SPVs verifies once and the same code is quoted on five separate confirmation statements over the following year. For depth on the identity-verification mechanic, see our commencement-day deep-dive on the 18 November 2025 commencement, our complete guide to identity verification in the UK, our page on the Companies House emails about verification, and our operational walkthrough for landlord LtdCos.

The ACSP Framework

The Authorised Corporate Service Provider (ACSP) regime sits alongside GOV.UK One Login as the second route to identity verification. ECCTA s.66 establishes the framework: AML-supervised firms (under the Money Laundering Regulations 2017) that have separately registered with Companies House as ACSPs can perform identity verification on behalf of clients.

Most established UK accountancy and company-secretarial firms are already AML-supervised by HMRC, ICAEW, ACCA, ICAS, or CIOT (the relevant supervisory bodies under MLR 2017). The ACSP registration with Companies House is procedural rather than substantive: the supervisory regime already exists, and ACSP registration adds a Companies House-side notification on top of it.

The ACSP route typically charges a fee in the £20 to £100 range per natural person (verify the precise figure with the specific firm; firm-published price lists vary). The route is particularly efficient where the firm already holds the client's KYC documentation under MLR 2017, because the firm can use that documentation to perform the Companies House verification without the client repeating any document upload. For a multi-SPV family group, the ACSP route is often the easier operational choice because the firm batches the family verifications, lodges the personal codes into its confirmation-statement workflow, and produces a single combined invoice.

The Abolition of Local Registers

ECCTA ss.51-52 abolished the local registers that companies previously had to maintain at the registered office for directors, company secretaries, and persons with significant control. All such information now consolidates at the Companies House central register; companies no longer keep separate local copies.

The change is procedurally minor for a landlord LtdCo (most modern SPVs were not actively maintaining a separate local PSC register beyond the statutory minimum), but it changes the source-of-truth model: the central Companies House Find and update company information service is now the only authoritative source for PSC and director data. Practitioner workflows that previously relied on inspecting a local register at the registered office (lender DD, JV-partner DD, sanctions screening) now route through the central service.

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ECCTA Part 2 and the Limited Partnership Reforms

ECCTA Part 2 brings limited partnerships registered under the Limited Partnerships Act 1907 into a Companies-Act-2006-style regime: registered office, annual confirmation, general-partner identity verification routed through the ACSP regime, striking-off powers, and information-disclosure obligations. The rollout is phased; the operative state moves and is best tracked through the Companies House campaign page (see operative-state pointer below).

For landlord LtdCo portfolios that consist solely of UK-incorporated companies under the Companies Act 2006, Part 2 is not directly relevant. It becomes relevant where any portfolio vehicle is a limited partnership: property-fund limited partnerships (the English limited partnership is the dominant vehicle for UK real-estate fund finance), joint-venture development LPs, and family-investment LPs holding tenanted property. Where any such vehicle is in the portfolio, monitor the campaign page for the Part 2 phased commencement.

The Landlord-LtdCo Compliance Roadmap

For a typical five-SPV landlord portfolio with one to two natural persons across the directorships and PSC roles, the next twelve months of compliance work follow a clean roadmap.

Q1 (December 2025 to January 2026). Inventory: list every UK company in the portfolio, and every natural person who holds a director or PSC role across them. Book the identity verification for each natural person (One Login is free and self-service; ACSP is a small fee with batched workflow). Target completion of the verification batch by end of January 2026, before any company's confirmation statement falls due.

Q1 to Q2 (January to March 2026). At each SPV, audit the registered email (it should be in place and active) and the registered office (it should meet the appropriate-address test). Reroute any PO-box-only registered offices.

Q2 to Q3 (rolling, on each SPV's confirmation statement filing date). File the confirmation statement with verified personal codes for every director and PSC, the lawful purposes statement, the registered email confirmation, and the appropriate-address registered office. Fee £50 online per SPV (verify the current figure at write).

Q3 to Q4 and beyond. Monitor trigger events: any new appointment requires pre-verification of the incoming director, any change of registered office or email is a notifiable change, and any Register of Overseas Entities updating statement (where applicable) is due within 14 days of the end of the update period.

Total cost for the five-SPV example: One Login verification £0 per person plus confirmation statement fee £50 per SPV per year (so £250 across five SPVs), plus any registered-office reroute cost. Time cost: roughly eight to fifteen hours of director or accountant time across the year, concentrated around the verification batch and the confirmation-statement filings.

Misframings to Avoid

Five misframings of the ECCTA architecture are common enough in third-party coverage to be worth correcting explicitly.

The Register of Overseas Entities is in ECCTA 2023. No. RoE primary anchor is ECTEA 2022 c. 10. ECCTA Part 3 amends it but is not the originating statute. The 2022 Act remains operative.

Schedule 12 of ECCTA 2023 amends ECTEA 2022. No. Schedule 12 is Criminal liability of bodies: economic crimes (failure to prevent fraud), a Part 5 matter. The ECTEA amendments sit in ECCTA Part 3.

ECCTA 2023 Part 1 is organised by Chapters. No. Part 1 is organised by section-grouped crossheadings. The crossheadings include Registrar's objectives (s.1), Company formation (ss.2-7), Company names (ss.8-22), Business names (ss.23-27), Registered offices (ss.28-30), Disqualification (ss.31-39), Directors (ss.40-45), Register of members (ss.46-50), Abolition of local registers (ss.51-52), Confirmation statements and lawful purposes (ss.59-63), and Identity verification (ss.64-69). There is no Chapter structure within Part 1.

ECTEA 2022 s.8 is removal from the register. No. ECTEA s.8 is the failure-to-comply criminal offence. Removal from the register on application is a separate matter at s.9.

ECTEA 2022 s.34 is the HMLR disposition-block. No. ECTEA s.34 is the compulsory-registration-notice power for unregistered overseas entities owning UK land. The HMLR disposition-block sits at Land Registration Act 2002 Sch 4A (inserted by ECTEA 2022 Sch 3).

If a source you are reading repeats any of these misframings, treat the source with caution; if a brief you are writing repeats them, correct it before publication.

Where to Track the Operative State

Two canonical sources for the current rollout state. Primary: the Companies House campaign page at changestoukcompanylaw.campaign.gov.uk, with topic sub-pages for identity verification, Authorised Corporate Service Providers, confirmation statement changes, and changes to company registers. Secondary: the Companies House blog at companieshouse.blog.gov.uk for operational announcements and phase-rollout posts. The legacy gov.uk/government/news/changes-to-uk-company-law URL is no longer active and should not be relied on.

Authorities Cited