Companies House drops pre-registration reporting section from update guide

Overseas entities filing update statements no longer face the announced pre-registration reporting section.GOV The update-statement page has lost its entire "Providing information about the pre-registration period" sectionGOV, which said filers would at a later date have to report beneficial-ownership changes during the pre-registration window, describing the requirement as introduced under the Economic Crime and Corporate Transparency Act 2023. That announcement and all its detail are gone.

What was removed starts with the window itself. The pre-registration period ran from 28 February 2022 to either the end of the transition period on 31 January 2023 or, for earlier registrants, their own registration date. Where the entity was the registered owner of UK property or land during that window, the next update statement was to carry additional information: whether the entity had any registrable beneficial owners, trusts involved in the entity, or beneficiaries of such trusts during the window, with information about each unless already reported. Managing officers were expressly excluded — filers did not need to report them for the pre-registration period. The information was to have been verified by a UK-regulated agent no more than 3 months before the update-statement date, and a filer unable to supply everything was told to file on paper and contact enquiries@companieshouse.gov.uk for guidance.

Everything else on the page is unchanged. Every overseas entity on the Register of Overseas Entities must still file an update statement each year, even with nothing changed, confirming the register entry or updating it. The statement date falls within a year of registration or of the last statement, with 14 days to file before the filing counts as late and a 12-month cap on what one statement can cover. Late filing remains a criminal offence carrying prosecution or a financial penalty, invalidates the overseas entity ID so UK property cannot be bought, sold, transferred, leased or charged, and draws a public-record note. Changes and newly added beneficial owners or managing officers must still be verified by a UK-regulated agent — UK-based, supervised under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 — no more than 3 months before the statement date, with an agent assurance code. Trust information can now be filed online, filing needs a Companies House account, the entity ID and authentication code, a contact name and the £134 card fee.

The statute book contains a transitional-cases duty the guidance page no longer mentions. Section 43A of the 2022 Act, inserted by section 174 of and Schedule 7 to the 2023 Act, requires overseas entities in scope to deliver further information for transitional cases under Schedule 6: statements about who became or ceased to be a registrable beneficial owner during the relevant period, information about trusts and trust beneficiaries, a statement of compliance with the duty to take steps to obtain information, verification material and contact details. The Schedule covers entities registered when it comes into force, or registered at any earlier time, that were proprietors of a relevant interest in land during the relevant period, alongside certain transitional-case offenders; its relevant period runs from 28 February 2022 to 31 January 2023. Delivery falls due with the first section 7 update after the 3-month window from commencement, with a removal application, or within 3 months for entities not then registered.

Legal basis: Economic Crime (Transparency and Enforcement) Act 2022, sections 7 (updating duty), 8 (failure to comply offence) and 43A with Schedule 6 (transitional-cases duty), the last inserted by section 174 of and Schedule 7 to the Economic Crime and Corporate Transparency Act 2023.