There are two changes that may be of interest to lenders:

1) Filings requiring identification

As seasoned lenders will be aware, you must file any mortgages, charges or security granted by a Company within 21 days of it being dated, in order to ‘perfect’ the security and maintain priority against other creditors. 

As part of the implementation of the ECCTA, Companies House will require identity verification for those delivering filings to Companies House.

They have introduced a scheme for third party service providers (solicitors, accountants or company formation services) to become ‘Authorised Corporate Service Providers’ (ACSP’s) to enable those persons to file on behalf of a company.

If you are a lender who normally completes their own filings at Companies House in respect of any security granted by borrowers, you will need to register for the ACSP scheme and may need to show that you are registered with a relevant supervisory body for anti-money laundering purposes.

The current timelines suggest identity verification for filings is likely to be compulsory as of Spring 2026, however, a year earlier (Spring 2025), Companies House should be able to carry out the checks to start the process to allow registration as an ACSP.

Further updates on the ACSP scheme are due to be published later this year: Authorised Corporate Service Providers - Changes to UK company law

2) PSC Register to be abolished

Directors and ‘persons of significant control’ will need to verify their identity with Companies House (both for new incorporations and existing companies) commencing this autumn. Once that process is complete, the intention is that companies will no longer have a PSC register, as such information will be filed and updated at Companies House. Lenders will therefore need to consider removing this as a ‘condition precedent’ from their loan documentation – the process is likely to be complete in late 2026.