If your company operates in the UK, the clock is ticking. Several key deadlines under the Economic Crime and Corporate Transparency Act (ECCTA) are hitting in late 2025 and 2026. From new fraud liability rules to mandatory identity verification for directors, these changes will reshape how companies manage governance and compliance. The bottom line: the rules are getting stricter and important deadlines are fast approaching, so prepare now.
What Is the UK’s ECCTA?
The ECCTA became law in October 2023 to build on earlier UK laws targeting bribery and tax evasion. Think of the ECCTA as the next step in the UK’s broader effort to make companies more accountable when financial crime happens inside their walls.
Before ECCTA, prosecutors had to rely on the “directing mind and will” test, which essentially entailed proving that top executives were personally involved in wrongdoing. That was a high bar which allowed some companies to escape liability even when serious misconduct happened. ECCTA changes that by introducing a new “senior manager” test: if a senior manager commits fraud, bribery, or sanctions violations while acting in their role, the company itself can be on the hook.
September 2025: Failure to Prevent Fraud Offense Goes Live for the ECCTA
One of the most significant changes comes into effect on September 1, 2025. The new “failure to prevent fraud” offense applies to large organizations (defined by the ECCTA as those meeting at least two of these thresholds: more than 250 employees, over £36 million in turnover, or more than £18 million in assets. If someone connected to the business commits fraud and the company didn’t have “reasonable prevention procedures” in place, the organization can face criminal liability. The penalty? Unlimited fines.
This echoes the UK’s earlier “failure to prevent” rules on bribery and tax evasion. The government is sending a clear message: companies are expected to be proactive, not reactive, in fighting fraud.
November 2025: ECCTA Identity Verification Becomes Mandatory
On November 18, 2025, new directors and people with significant control (PSCs) must verify their identity with Companies House (the UK’s official corporate registry). Existing directors have a 12-month grace period to complete the process.
Why does this matter? Because, under the ECCTA, the Companies House now has new powers. It can query, reject, or remove filings. It can issue fines of up to £10,000, and in some cases non-compliance can even lead to imprisonment. Historically, Companies House was a passive record keeper. Now it’s an active regulator with teeth.
Spring 2026: Authorized Corporate Service Providers (ACSPs)
By spring 2026, another compliance layer will take effect. Third-party agents (for example, accountants or company formation agents) who file on behalf of companies must be registered as Authorized Corporate Service Providers. Identity verification of presenters will also become mandatory. This adds an extra compliance step for international businesses that rely on local service providers to manage filings.
ECCTA Next Steps: What US-based Companies Should Do Now
If your US-based company has operations in the UK, here’s what you should be doing right now to get ahead of ECCTA:
- Audit senior management roles. Map out where fraud risks might sit. Don’t assume liability stops at the C-suite—under ECCTA, senior managers bring exposure too.
- Update or launch fraud prevention policies. Have written procedures that are proactive and put into practice. Train managers so they know how to spot and stop fraud.
- Brief your leadership. Senior managers need to understand both their own personal liability and the company’s risk. Don’t wait until September 2025 to have that conversation.
- Plan for ID verification. Set up your processes well before November 2025. Decide whether to use the UK’s government login system or work through an ACSP. Internal communication now is critical to avoid missed deadlines.
- Strengthen board reporting and culture. Make fraud and compliance updates a standing agenda item. Go beyond systems—foster a culture of accountability where prevention isn’t just compliance, it’s part of how your company operates. Your company secretary (CoSec) can play a key role here, ensuring filings, ID checks, and governance practices run smoothly.
- Factor in costs and operational impact. Verification fees, process bottlenecks, and system upgrades may hit SMEs harder than larger firms. Plan budgets accordingly and look for external experts well versed in navigating global corporate transparency and liability compliance if your internal resources are thin.
Doing these now reduces the scramble later—and positions your company to handle ECCTA as part of a bigger governance strategy.
Beyond the ECCTA: The Bigger Picture In UK Corporate Accountability
It’s worth remembering that ECCTA is one piece of a larger trend. Regulators in the UK and elsewhere are tightening rules, but every country does it differently. That patchwork makes compliance harder for companies that operate overseas across different countries. Beyond the UK, each EU country, from France and Germany to Spain and Hungary—has its own way of approaching fraud, liability, and corporate transparency.
ECCTA also doesn’t sit in isolation in the UK—it comes alongside greater scrutiny from other financial and transparency reforms, namely the Financial Conduct Authority (FCA) and changes in the Finance Act 2024. Taken together, these point to a pattern of tougher oversight on both financial conduct and tax matters. Companies that view compliance holistically—rather than law by law—will be best positioned to keep up.
That’s why building governance systems that are clear, consistent and easy to adapt matters. ECCTA’s deadlines are specific to the UK, but the underlying message is global: companies must take more responsibility for preventing financial crime and ensuring transparency.
Final Thoughts
For U.S. companies in the UK—or thinking about expansion there—the urgency is clear. September 2025 and November 2025 aren’t far away, and spring 2026 isn’t either. Companies that start preparing now will be in far better shape than those that wait.
The old way of treating compliance as a formality is over. Regulators are expecting action, not lip service. ECCTA is yet another part of this trend toward stricter corporate liability and transparency through legally enforceable obligations. If your company has operations in the UK, start preparing now to ensure that your directors are verified on time, your fraud prevention procedures are in place, and your governance systems are strong enough to withstand stricter regulatory scrutiny.
At HSP, our global compliance experts support global companies as they navigate complex sustainability regulations. If your business needs guidance preparing for the ECCTA or managing other global compliance obligations, reach out to our team today.
HSP is an end-to-end global expansion solutions provider focused on helping companies scale their operations overseas effectively and efficiently. We are the only global expansion expert to offer growing companies a full suite of end-to-end solutions designed to help them scale to any size and country.
Our in-country experts have delivered the full spectrum of global expansion solutions—from EoR to entity set-up and management—across more than 100 countries (and counting). HSP brings full payroll, accounting, tax, legal, compliance, and HR services to corporate teams, integrating with in-house staff to both guide and execute across every domain.
Contact us to discover how our full suite of global mobility services can help your company successfully operate overseas in any environment.
