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ECCTA And The Register Of Members

Friday, 22 August 2025

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) represents one of the most significant overhauls of UK corporate law and financial crime legislation in recent times. It is focused on tackling economic crime and improving corporate transparency.

Nearly two years after receiving Royal Assent in October 2023, the implementation of the legislation continues. One implementation area is changes to the Register of Members (s113).

S113, Register of Members, will have a new definition of name and new powers to obtain that information. It is intended to enhance and standardise member name information – with both a forename and surname required. There will also be a new section, s113F, added to give power to a company to require information from members. A company exposes itself to the risk of prosecution if the Register of Members does not contain the required information.

So, what’s changed?

A forename and surname are required for each member on the register. Currently, a name could use an initial rather than full forename, or just one name, for example.

What’s next?

We are waiting for secondary legislation to implement these changes with a definitive date to be set by the Department for Business and Trade (DBT).

Our position:

Through our membership of the industry group, CGI Registrars Group, we continue our engagement with DBT on the Companies Act changes relating to the Register of Members.

Key highlights:

  • Minimum 12 months’ notice of implementation: we have requested a minimum of 12 months’ notice be given for the changes to come into effect through secondary legislation.
  • Industry standard shareholder communications: we are working to prepare industry standard communications for shareholders for non-compliant shareholders.
  • Clarification of actions and evidence a company needs to have: The company is under a duty to have the required information about members in its Register of Members and record the date on which the person was registered as a member. We are working as an industry to agree a standard approach for auditing the current information, and procedures going forwards for a new member on the register.
  • Effective co-ordination with the changes proposed for digitised share registers: with additional changes proposed to deliver a digitised share register by the end of 2027, we are seeking to discuss how we can effectively communicate with shareholders for both the ECCTA changes, and the proposals set out for a Digitised Share Register and removal of share certificates.

Need help navigating ECCTA?

Please reach out to your Relationship Manager who will be able to assist further, or find more information on our dedicated ECCTA Hub.

Visit the ECCTA Hub
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