The Economic Crime and Corporate Transparency Act 2023 will require every company to record each individual shareholder’s forename and surname, and a service address, in its register of members, and to file a one off full shareholder list with its next confirmation statement. Shareholders will have a legal duty to give the company this information. As at October 2026 these rules have been enacted but not commenced, and Companies House says it is still working through implementation options.
What is wrong with shareholder names on the register today?
Section 113 of the Companies Act 2006, as it currently applies, requires the register of members to contain the names and addresses of the members, the dates they joined and left and, for a company with share capital, the shares each holds. The Act does not define “name”. The government’s factsheet on improving transparency of company ownership says this has allowed entries such as “T Smith” where users of the register need “Trevor Smith”. The same names flow to Companies House through the confirmation statement, because section 853F requires a non traded company to give each member’s name “as it appears in the company’s register of members”. This page covers the new identity details only; the wider rules on keeping and inspecting the register are explained in statutory registers.
What will the register of members have to show?
Section 46 of the 2023 Act substitutes a new section 113(2). For each member the register must contain the “required information” and the date of registration as a member, with the date membership ceased entered separately (new section 113(2A)). The required information is:
- Individuals (new section 113A): name and a service address, where “name” means forename and surname. A peer or someone usually known by a title may be entered by that title.
- Bodies corporate and firms that are legal persons (new section 113B): the corporate or firm name and a service address.
The share details in section 113(3) stay the same: the shares held, distinguished by number and class, and the amount paid up. Joint holders are still named individually and treated as a single member, with a single service address. Section 113C lets the Secretary of State change the required information by affirmative regulations.
What must shareholders do?
For the first time, members themselves will owe duties to the company:
- A person who becomes a member must give the company the required information within two months of becoming a member, unless already provided or included in the incorporation application (new section 113D).
- A member must notify the company of any change in the required information, stating the date of the change, within two months of it happening (new section 113E).
- A company may serve notice on a member or former member requiring the information, and the recipient must comply within one month (new section 113F).
Failing without reasonable excuse to comply with any of these is an offence under new section 113G. On indictment the maximum is two years’ imprisonment, a fine, or both. A misleading, false or deceptive statement made without reasonable excuse is a summary offence under section 113H, and a knowingly false statement can lead to up to two years’ imprisonment under section 113I. Where a corporate member is at fault, every officer in default also commits the offence. The company’s own offence for not keeping the register properly remains in section 113(7), with a new reasonable excuse qualification.
Will old details have to be kept?
Yes, for private and other non traded companies. New section 113(6A) says that where any information in the register changes, the company must keep the old information until its removal is authorised by section 121 or a court order, and add a note of the date the information changed and the date the change was entered. Section 121 allows an entry for a former member to be removed ten years after they ceased to be a member. Traded companies need not keep the old information (section 113(6B)). In practice the register becomes a history, not a snapshot, so overwriting a shareholder’s old address or name in a spreadsheet will no longer be acceptable.
What will go to Companies House?
Section 50 of the 2023 Act requires a one off statement. On the first confirmation statement with a confirmation date after an appointed day, a company registered before that day must also deliver:
| Type of company | Information in the one off statement |
|---|---|
| Non traded company | The name, as it appears in the register of members, of every member at the end of the confirmation date, and the number of shares of each class each of them held |
| Traded company | The name and address of each person holding at least 5% of the issued shares of any class at the end of the confirmation date, and their holdings |
Failing to deliver it is treated in the same way as failing to deliver the confirmation statement. The factsheet says the full list will let Companies House display shareholder information in a more user friendly way, and that the information will be public on the register. After that, the ordinary section 853F return of names, holdings and transfers continues each year, but the names will be the full names held in the new style register.
Can shareholders’ details be protected?
Section 48 of the 2023 Act inserted a new section 120A into the Companies Act 2006. It allows the Secretary of State to make regulations requiring a company to refrain from using or disclosing individual membership information except in specified circumstances, and to let the registrar make protection orders on application. Breach of such a restriction would be an offence by the company and every officer in default (section 120B). Separately, the new required information is a service address, which section 1141 defines as an address at which documents may be effectively served on the person, so it need not be a home address.
A related change is already live. Since 4 March 2024, section 125 has allowed the person aggrieved, any member or the company to apply to court to rectify the register where it does not include information it is required to include, or includes information it is not required to include.
When will the changes start?
Legislation.gov.uk shows sections 113 to 113I with the 2023 Act amendments in force only for the purpose of making regulations, with no commencement for the substantive duties as at mid October 2026. The appointed day for the one off statement has not yet been set. Companies House’s outline transition plan, updated on 5 August 2026, says the publication of more shareholder information will be a significant undertaking for some companies and that it is working through the implementation options. Companies have time, but the information gathering is easier to do now than in a rush after commencement.
How should a company prepare?
Illustration only. A family company has five shareholders. Its register lists “J Patel”, “Mrs A Jones”, “Smith Holdings” and two grandchildren who received shares on their grandfather’s death and whose entries still show his address. To be ready, the company secretary:
- collects each individual’s forename and surname exactly as on their identity documents;
- confirms the full registered name of “Smith Holdings Limited” and its service address;
- agrees a service address with each member at which documents can be effectively served;
- checks that past share transfers and transmissions have actually been entered, because the one off list must match the register;
- keeps the old entries rather than overwriting them, ready for the history rule.
What mistakes should companies avoid?
- Correcting names in the confirmation statement but not in the register itself. The statutory return copies the register, so the register must be fixed first.
- Assuming nominees or bare trustees are excluded. In England, Wales and Northern Ireland no notice of any trust may be entered on the register (section 126), so it is the nominee’s details that are required (see nominee shareholders).
- Treating initials as acceptable once the rules commence. The statutory meaning will be forename and surname.
- Deleting former members’ entries early. The ten year period in section 121 still applies.
- Confusing this with identity verification. Ordinary shareholders do not have to verify their identity under these provisions; that regime applies to directors and people with significant control.
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Sources
- legislation.gov.uk: Act 2006 c. 46, section 113
- legislation.gov.uk: Act 2006 c. 46, section 113A
- legislation.gov.uk: Act 2006 c. 46, section 113B
- legislation.gov.uk: Act 2006 c. 46, section 113C
- legislation.gov.uk: Act 2006 c. 46, section 113D
- legislation.gov.uk: Act 2006 c. 46, section 113E
- legislation.gov.uk: Act 2006 c. 46, section 113F
- legislation.gov.uk: Act 2006 c. 46, section 113G
- legislation.gov.uk: Act 2006 c. 46, section 113H
- legislation.gov.uk: Act 2006 c. 46, section 113I
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.
