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EQ Monthly Bulletin - October 2025

Monday, 27 October 2025

Keeping you up to date with industry changes and news impacting the world of share registration and employee share plans.

Welcome to our October edition of the EQ Bulletin.

Economic Crime and Corporate Transparency Act Updates

Joint Committee on Statutory Instruments

On 12 September 2025, the Joint Committee on Statutory Instruments published its report that includes clarification on implementation of the Economic Crime and Corporate Transparency Act 2023 (ECCTA).

The Committee requested clarification from the Department for Business and Trade on how certain provisions of the Companies Authorised to Register, Unregistered Companies and Overseas Companies (Application of Company Law) Regulations (Regulations) and the ECCTA will come into force.

The Department for Business and Trade confirmed that it intends to commence section 167M of the Companies Act 2006 (prohibition on director acting unless identity verified) at the same time as section 59 (confirmation statements) and schedule 2 (abolition of certain local registers) at the same time, this enacts elements of both ECCTA and the Regulations.

The Joint Committee Report can be accessed here: Thirty-fourth Report of Session 2024-26

Companies House

On 22 September 2025, Companies House published the Register of Overseas Entities Rules 2025, setting out the form, manner of delivery and method of authentication for documents delivered to Companies House following the establishment of the Register by the Economic Crime and Corporate Transparency Act (ECCTA).

The Rules include:

  • Documents must be delivered in electronic form using the Companies House online portal
  • Register of Overseas Entity verification statements must be delivered via a presenter in possession of an agent assurance code
  • Documents that are protected must be sent in paper form (those which contain information about beneficial owners or officers whose personal information is protected)
  • Details about the manner in which documents must be authenticated and who may authenticate them

The Rules came into force on 16 September 2025.

The Register of Overseas Entities Rules can be accessed here: Register of Overseas Entities Rules 2025

Economic Crime and Corporate Transparency Act 2023 (Consequential, Incidental and Miscellaneous Provisions) Regulations 2025

On 23 September 2025, the Economic Crime and Corporate Transparency Act 2023 (Consequential, Incidental and Miscellaneous Provisions) Regulations 2025 were published, to enact the provisions to remove the requirement for companies to maintain their own registers.

Other provisions in the Regulations include:

  • Authorised Corporate Services Providers to provide an anti-money laundering registration number
  • Individuals to provide their unique identifier codes
  • Suppression of certain identity verification statements

The regulations come into force at the same time as Section 43 of the ECCTA comes into force.

The statutory instrument is available here: The Economic Crime and Corporate Transparency Act 2023 (Consequential, Incidental and Miscellaneous Provisions) Regulations 2025

The explanatory memorandum is available here: The Economic Crime and Corporate Transparency Act 2023 (Consequential, Incidental and Miscellaneous Provisions) Regulations 2025

Limited Liability Partnership (Application and Modification of Company Law) Regulations 2025

On 23 September 2025, the Limited Liability Partnership (Application and Modification of Company Law) Regulations 2025 were published, bringing into force certain requirements under the ECCTA for LLP members.

The Regulations will come into force when sections 167M, 790LA and 167G of the Companies Act 2026 come into force.

The statutory instrument is available here: The Limited Liability Partnerships (Application and Modification of Company Law) Regulations 2025

The explanatory memorandum is available here: The Limited Liability Partnerships (Application and Modification of Company Law) Regulations 2025

Register of People with Significant Control (Amendment) Regulations

On 23 September 2025, the Register of People with Significant Control (Amendment) Regulations 2025 were published, amending requirements introduced by the ECCTA, relating to the reporting of PSC information directly to Companies House.

The Regulations come into force when section 790LA of the Companies Act 2006 comes into force.

The statutory instrument is available here: The Register of People with Significant Control (Amendment) Regulations 2025

The explanatory memorandum is available here: The Register of People with Significant Control (Amendment) Regulations 2025

London Stock Exchange Market Notice N10/25

On 12 September 2025, the London Stock Exchange published Market Notice N10/25, which confirms that no further amendments have been proposed to the draft Admissions and Disclosure Standards published under Market Notice N09/25 (amendments specific to PISCES).

The revised Admission and Disclosure Standards came into force on 15 September 2025.

The Market Notice is available here: n1025.pdf

The revised Admission and Disclosure Standards are available here: LSEG Admission and Disclosure Standards

Annual Review of Corporate Reporting

On 30 September 2025, the FRC published its Annual Review of Corporate Reporting for 2024/2025, outlining the top ten areas where the FRC considers improvements to reporting are required.

The FRC’s expectations for companies for the next reporting season include:

  • Pre-issuance checks
  • Judgements, risks and uncertainties
  • Narrative reporting – particularly the strategic report

In addition, the FRC expects companies to take a step back to consider their reports as a whole. Recommending reports should:

  • Tell a consistent story
  • Be clean, concise and understandable
  • Include all material and relevant information

Include only material and relevant information

The Annual Review can be accessed here: Annual Review of Corporate Reporting

Dematerialisation Market Action Taskforce

On 9 October 2025, HM Treasury announced the appointment of Mark Austin CBE to establish and Chair the Dematerialisation Market Action Taskforce (DEMAT) and published Terms of Reference, setting out its objectives and governance structure.

The establishment of DEMAT follows the Digitisation Taskforce recommendation in its final report published on 15 July 2025 for proposed reforms to the UK’s shareholding framework.

The government has asked DEMAT to:

  • Report back by summer 2026 with a recommended “go live” date for the replacement of paper based “certified” share registers by “digitised” share registers, by the end of 2027, with an implementation plan (Step 1)
  • Begin working with market participants to identify and implement the actions needed as part of Step 2, with the aim of market readiness for Step 3 by the end of the current parliament
  • Assess progress in implementation, with government having provided criteria for assessing readiness for Step 3

The HM Treasury Policy Paper on DEMAT can be accessed here: Dematerialisation Market Action Taskforce - GOV.UK

The Terms of Reference can be accessed here: Terms of Reference for Dematerialisation Market Action Taskforce (DEMAT) - GOV.UK

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