In the third part of our series on ‘Uncovering ECCTA’, we look at changes to the statutory registers that companies are required to keep and explore the new approach to data centralisation. Although the information below relates to private limited companies, we expect the same to apply to LLPs.
What Are Statutory Registers?
Statutory registers are a collection of official records that a company is legally required to maintain. They provide a historical and current record of the company’s structure, ownership and key individuals responsible for its operation and control.
At the moment, companies are required to keep the following registers:
Many companies also keep additional registers such as Allotments and Transfers.
What Is Changing?
Under the ECCTA, from November 18, 2025, companies will no longer be required to maintain certain internal statutory registers. Specifically, companies will no longer need to keep their own registers of directors, directors’ residential addresses, secretaries, and PSCs.
Companies will need to ensure that the details they file with Companies House relating to directors, secretaries and PSCs are accurate and current, as this will now form the definitive centralised record.
With an increased focus on accuracy, failure to comply with filing requirements and deadlines can lead to penalties.
Register Of Members
In a contrast to the other registers, the ECCTA treats the Register of Members differently.
The option for companies to keep their Register of Members on the central register at Companies House is being removed and any company that had previously chosen to do this will now be required to create and maintain their own register internally. The reason for this is that the IDV regime does not apply to all shareholders, meaning Companies House cannot be the sole source of information about ownership.
In addition, under the ECCTA, members will be obliged to provide accurate information to the company, including their full forename and surname. A member who fails to provide this information without reasonable excuse will be committing a criminal offence.
The Register of Members must contain:
Companies will also be required to submit a one-off full list of shareholders to Companies House via their next confirmation statement, ensuring that a baseline of this information is centrally available while the day-to-day management of the register remains with the company.
What Other Registers Must A Company Maintain?
Other Registers that need to be maintained are:
While not classified as ‘Statutory Registers’, companies are also legally required to maintain the following important records:
Where should Registers be Stored?
Statutory registers must be kept at the company’s registered office or at a Single Alternative Inspection Location (SAIL) address, which must be notified to Companies House.
The registers must be available for inspection by members of the public and company members. Company members have the right to inspect the registers for free. Members of the public can also request to inspect and copy the registers for a prescribed fee, provided the request is for a proper purpose.
Why Now?
This change is a direct consequence of the new IDV regime. As Companies House will now be the centralised source of verified data for these roles, the internal registers will become redundant.
While no longer a legal requirement, many companies may choose to continue maintaining these records for their own due diligence, good governance or internal housekeeping purposes. It should also be noted that, as RLEs are not currently covered under IDV, it is a good idea to maintain the PSC register if your company has an RLE instead of a PSC.
If you have any questions in the meantime about what this means for you and your company, please contact us on contact@prosec-cosec.com
