Since 4 March 2024 the registrar of companies has had a general power, in section 1110F of the Companies Act 2006, to disclose information to any public authority for that authority’s functions and to anyone for purposes connected with the registrar’s own functions. Anyone may also pass information to the registrar under section 1110E, and section 1062A requires the registrar to analyse what it holds to prevent or detect crime. The main limits are data protection law and special controls on information that came from HMRC.
What powers did the 2023 Act add?
Section 94 of the Economic Crime and Corporate Transparency Act 2023 inserted three sections into Part 35 of the Companies Act 2006 under the heading “Disclosure of information”. They came into force for specified purposes on 26 October 2023 and otherwise on 4 March 2024.
- Section 1110E, disclosure to the registrar. Any person may disclose information to the registrar for the purposes of the exercise of any of the registrar’s functions.
- Section 1110F, disclosure by the registrar. The registrar may disclose information to any person for purposes connected with the registrar’s functions; to a public authority for purposes connected with that authority’s functions; and to a person of a description, and for a purpose, specified in regulations. “Public authority” includes any person or body having functions of a public nature.
- Section 1110G, supplementary. Disclosures under either section do not breach any obligation of confidence or other restriction on disclosure, subject to data protection law and to the HMRC rules described below.
The government’s factsheet on the role and powers of the registrar explains the background. Under the original 2006 Act the registrar’s role was to register company information and make it available for public inspection, with limited powers to protect its accuracy. The 2023 Act added new objectives, including one in section 1081A to prevent companies and others from carrying out unlawful activities or facilitating them, and gave the registrar data sharing powers to support those objectives. The broader set of powers is covered in Companies House powers to query and remove information.
Who can Companies House share information with?
The factsheet says the registrar can proactively disclose information to:
- public authorities, including any government body, local authorities (including trading standards) and any person or body discharging functions of a public nature, including regulatory functions;
- law enforcement bodies, such as police forces, the Insolvency Service, the National Crime Agency and the Serious Fraud Office;
- the supervisory bodies listed in the Money Laundering Regulations; and
- insolvency practitioners.
The Companies House enforcement policy adds that it works with police and law enforcement including the National Crime Agency, the Financial Conduct Authority, the Insolvency Service, the Foreign, Commonwealth and Development Office, HM Treasury and HMRC. It says it shares intelligence, threat analyses, insight and tactics, refers cases that fall within other bodies’ jurisdiction, and will set these arrangements out in protocols and memoranda of understanding. Where a referral reaches the Insolvency Service, see company investigations by the Insolvency Service.
What information can be shared?
According to the factsheet, the power covers all information Companies House holds about any entity, across the whole life cycle of an individual’s or company’s dealings with it. This is most significant for information the public cannot see. The Companies House personal information charter explains that a director’s usual residential address and the day of their date of birth are collected but kept off the public register, and that supporting information given to verify identity is not made public either. It adds that, as with other non public data, Companies House may obtain and share this information where appropriate or necessary for lawful purposes.
Two older disclosure routes still run alongside the new power:
- section 243(2) lets the registrar disclose protected residential address information to credit reference agencies, and the charter says full date of birth can also go to credit reference agencies unless the person qualifies for protection;
- regulations under section 243 let a director apply to stop disclosure to credit reference agencies, and since the 2023 Act those regulations can give the registrar a discretion in deciding such applications.
Our page on directors’ residential address protection explains the application routes.
Where does the information come from?
Information flows into Companies House as well as out:
- filings by companies, agents and authorised corporate service providers;
- voluntary disclosures by anyone under section 1110E, which can include tip offs from the public and data from other departments;
- answers to the registrar’s power to require information under section 1092A;
- discrepancy reports under regulations made under section 1110D, which can require businesses to report differences between what they know about a customer and what is on the register (see discrepancy reporting).
Section 1062A then requires the registrar to carry out such analysis of the information in its possession as it considers appropriate for preventing or detecting crime, and cross refers to section 1110F. The Companies House transition plan says that since 4 March 2024 it has been undertaking greater analysis of the information it holds, including comparison against data sets obtained externally, and that by no earlier than the end of 2026 it expects to facilitate greater cross checking of data between Companies House and other public and private sector bodies.
What limits apply?
Section 1110G sets the boundaries:
- Data protection. Sections 1110E and 1110F do not authorise a disclosure that would contravene data protection legislation, although the powers themselves are taken into account in deciding whether it would (section 1110G(2)).
- HMRC information. Information disclosed to the registrar by or for HMRC may not be passed on under section 1110F without HMRC’s authorisation, and a recipient may not pass it on further without that authorisation (section 1110G(3) and (4)).
- Criminal sanction. Disclosing revenue and customs information about an identifiable person in breach of those rules is an offence, with a defence of reasonable belief that the disclosure was lawful or that the information was already lawfully public (section 1110G(5) and (6)).
The personal information charter also says sharing only takes place in certain circumstances and only where the law allows. Section 1110F(1)(c) disclosures to private bodies need regulations approved by both Houses under the affirmative procedure.
How might this work in practice?
Illustration only. Companies House analysis finds 40 companies formed in a month at the same residential address, all with the same director, none of which has filed a document since incorporation. The registrar queries the filings, and the person living at the address reports that it is being used without consent. Under section 1110F the registrar can pass the pattern, the filing history and the non public identity information it holds to the police or the Insolvency Service for their investigation, and can share relevant details with an anti money laundering supervisor if a regulated firm formed the companies. HMRC data the registrar received about the same companies could only be passed on with HMRC’s authorisation.
What does this mean for directors and their advisers?
- Consistency is visible. Information given to Companies House can be compared with other bodies’ data, so filings that do not agree with other records are more likely to be noticed.
- Non public is not secret. Residential addresses, full dates of birth and identity evidence are kept off the public register, but can be shared with public authorities for their functions.
- Firms keep their own duties. Companies House sharing does not replace an accountant’s obligation to make a suspicious activity report; see suspicious activity reports for accountants.
- Agents are in scope too. The charter says personal data about applicants for authorised agent status may be shared with other government departments and enforcement agencies.
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Sources
- legislation.gov.uk: Act 2023 c. 56, section 94
- legislation.gov.uk: Act 2006 c. 46, section 1110F
- legislation.gov.uk: Act 2006 c. 46, section 1110E
- legislation.gov.uk: Act 2006 c. 46, section 1110G
- legislation.gov.uk: Act 2006 c. 46, section 1081A
- GOV.UK: Economic crime and corporate transparency act the role and powers of t
- GOV.UK: Companies house enforcement policy
- GOV.UK: Personal information charter
- legislation.gov.uk: Act 2006 c. 46, section 243
- legislation.gov.uk: Act 2006 c. 46, section 1092A
Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 8 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.
