ECCTA 2023: ‘is your company operating for lawful purposes?’ - Blake Morgan

Whilst this option is not so commonly used these days, from 26 January 2026, companies are no longer permitted to use the central register of members and are instead required to hold their own register of members.

The ECCTA has slightly amended the information to be recorded for each member on the register, bringing the requirements in line with that for directors and PSCs. The register must now record each member’s full first names, surnames and service address.

Except upon incorporation where this information is required in order to incorporate the company, the ECCTA now places the onus on the new member to provide their information within two months of becoming a member. However, a company can require the member to provide the information within only one month.

ECCTA introduces new offences where a member fails to provide their details (without a reasonable excuse) to the company, or they provide information that is misleading or false.

Register of directors, secretaries and PSCs

From 18 November 2025, the ECCTA has removed the requirement for companies to maintain their own:

Register of directors and secretaries;

Register of directors’ residential addresses; and,

However, the duty to inform the Registrar of changes of the above information remains. New information regarding directors, secretaries and PSCs, including notifications becoming or ceasing to be any of the aforementioned positions, must be filed at Companies House within 14 days .

It should be said that in practical terms it is likely that these registers, in some form, will continue to be kept as when a company is sold or reorganised the information these Registers contain will still be relevant. Additionally, this information is still part of the information which must be confirmed on the annual confirmation statement and so it is still sensible for a company to keep.