Significant changes to company registers requirements on 18 November 2025 - GBH Law

One of those changes is the introduction of mandatory identity verification requirements for company directors, members of LLPs and people with significant control (PSCs). You can read about this on our previous post.

However, that is not the only change affecting companies from 18 November 2025, there will also be significant changes to the law relating to company registers, and associated updates to notification requirements and other company obligations.

The current landscape

Companies are required to keep and maintain various registers (which are often referred to as the company’s ‘statutory books’). Some of the key registers are the:

• register of members;
• register of directors;
• register of directors’ residential addresses;
• register of secretaries; and
• PSC register.

The requirement to keep each of the registers above is subject to an option for private companies to keep each one on the public record at Companies House, instead of the company maintaining a ‘local’ register . To take that option, a formal election must be made and filed at Companies House. In our experience, only a very small proportion of companies have taken up that option and as such, the vast majority are required to keep their own registers.

Companies are also required to notify Companies House when relevant changes occur – for example, a new director or secretary being appointed, an existing appointment terminating, or changes relating to the company’s PSCs. However, assuming the company has not made an election to keep the relevant records on the public register (as referred to above), the information about these things held at Companies House does not constitute the registers – it is only a reflection of what is in the actual registers.

What’s changing on 18 November 2025?

• Companies are no longer required to keep any of the following:
  • Register of directors;
  • Register of directors’ residential addresses;
  • Register of secretaries;
  • PSC register.

Instead, the information about these things will be held centrally on the register at Companies House.

• Those changes are accompanied by updated (and augmented) requirements for notifying Companies House in relation to relevant changes, and also some associated points which help to bolster the requirements. For example, if somebody is appointed as a director but Companies House is not notified before the end of the requisite period (14 days beginning on the day they were appointed), that person is not permitted to act as a director and will be committing an offence if they do.
• There are also some other related changes, including expanded duties placed on companies and registered PSCs to ensure that the information held about a company’s PSCs is correct, and the creation of some new offences for failing to comply with notices, failing to provide information and false statements.
• Unsurprisingly, the option that was previously available to keep registers relating to directors, secretaries and PSCs on the central register is removed.

What’s not changing on 18 November 2025?

In short, the requirements relating to the register of members. This will still be something which must be maintained by the company ‘locally’ (certainly for most companies).

The ECCTA does include provisions to abolish the option to keep details of a company’s members on the central register at Companies House, and Companies House has previously announced that this option will cease on 18 November. However, it does not appear that anything has happened, yet, which would give legal effect to that – the secondary legislation which has brought the various other matters referred to in this post into force does not cover the abolition of this option. However, given that Companies House has made the announcement, it would seem prudent for any companies who are currently keeping details of their members on the central register to write up a register of members now.

Will companies be allowed to keep their own registers of directors, directors’ residential addresses, secretaries and PSCs after 18 November?

Yes. What’s being removed is the requirement to keep these registers. That does not mean that a company cannot choose to continue keeping such registers (even if they will become, for all intents and purposes, for reference/information only). Companies might decide that it is prudent to continue to maintain their own copies of the registers locally, as it seems quite possible that the information in them might prove to be helpful at one point or another (including if there is a significant event relating to the company – for example, a sale).

If you need any assistance in relation to any matter concerning company record keeping or any related matters, our company secretarial services may be of interest. If you would like to know more about this (or need any other corporate assistance) please contact any member of our Corporate Team.