UK Confirmation Statement Guide 2024: Everything CSPs Need to Know

The UK confirmation statement (form CS01) is the successor to the annual return and serves as the primary mechanism through which UK companies confirm the accuracy of information held at Companies House. For corporate service providers administering portfolios of UK-registered companies — whether private limited companies, public companies, or LLPs — filing confirmation statements accurately and on time is a core operational obligation. Recent reforms under the Economic Crime and Corporate Transparency Act 2023 (ECCTA) have materially changed the compliance landscape.

What Is the Confirmation Statement?

The confirmation statement (CS01) was introduced in June 2016, replacing the annual return (AR01). Unlike the annual return which required full restatement of company information each year, the confirmation statement operates on a "confirm and update" model: the company confirms that all information currently held by Companies House is accurate, and updates anything that has changed since the last confirmation.

Every UK company must file a confirmation statement at least once every 12 months. The 12-month period runs from the incorporation date (for new companies) or from the date of the last confirmation statement. Companies have 14 days after the end of the confirmation period to file — so effectively up to 12 months and 14 days from the previous filing date.

What Information Must Be Confirmed or Updated?

The confirmation statement covers the following key categories of information:

• Registered office address — must be a valid address in the company's jurisdiction of registration (England and Wales, Scotland, or Northern Ireland)
• Principal business activities — SIC codes (Standard Industrial Classification) reflecting the company's current activities
• Registered email address — a new requirement introduced by ECCTA 2023, applicable from March 2024
• Directors and secretaries — names, service addresses, dates of birth, nationalities, and appointment dates
• Share capital — current authorised and issued share capital structure
• Shareholders — statement of capital and list of significant shareholders (those holding 5% or more of any class of shares)
• PSC (Persons with Significant Control) register — updated information on all PSCs must be accurate at the confirmation date
• Trading status — confirmation of whether the company is currently trading

The PSC Register and Its Relationship to the Confirmation Statement

The Register of Persons with Significant Control (PSC register) is perhaps the most compliance-sensitive element of the confirmation statement process for CSPs. A Person with Significant Control is broadly equivalent to a beneficial owner — an individual who holds more than 25% of shares or voting rights, has the right to appoint or remove the majority of directors, or otherwise exercises significant influence or control over the company.

The PSC register must be maintained by the company on an ongoing basis — not just updated at the confirmation statement. Changes must be notified to Companies House via a PSC form within 14 days of the change being entered in the company's own PSC register, and within 14 days of the change itself. The confirmation statement then confirms the register is accurate as at the confirmation date.

For CSPs managing nominee arrangements, the PSC register treatment of nominees and underlying beneficial owners is a key compliance consideration. Where a nominee shareholder holds shares on behalf of an individual, that individual — rather than the nominee — should typically be registered as the PSC, unless the nominee company itself meets the PSC threshold in its own right.

ECCTA 2023: The Identity Verification Requirement

The Economic Crime and Corporate Transparency Act 2023 introduced identity verification requirements for directors, PSCs, and certain persons who file documents with Companies House. Identity verification is being phased in from 2024, with the following timeline:

• From Autumn 2024: new directors and PSCs must verify their identity before or shortly after appointment
• Existing directors and PSCs: a transition period during which existing officeholders can verify voluntarily, ahead of mandatory verification requirements coming into force
• Authorised corporate service providers (ACSPs): CSPs can verify identities on behalf of their clients as part of their authorisation under the new ACSP regime

CSPs administering UK company portfolios should monitor Companies House guidance closely as the verification requirements are phased in, and should update their onboarding and ongoing maintenance workflows to incorporate verification checks.

The Authorised Corporate Service Provider (ACSP) Regime

ECCTA 2023 introduces a new registration regime for companies that provide corporate formation and administration services to UK companies — Authorised Corporate Service Providers (ACSPs). ACSPs will be able to verify identities on behalf of clients and will be subject to anti-money laundering supervision as a condition of authorisation.

For CSPs currently providing UK company administration, the ACSP regime represents both an obligation (registration and AML supervision will be required to provide certain services) and an opportunity (authorised status enables value-added verification services for clients).

Filing the Confirmation Statement: Practical Notes for CSPs

Key operational points for CSPs filing confirmation statements on behalf of clients:

• Set compliance calendar reminders at 90, 30, and 14 days before each company's confirmation statement deadline
• Collect client confirmation of PSC information accuracy before each filing — do not assume prior-year information remains current
• The filing fee (currently £13 for online filing) must be paid at the time of filing — Companies House does not invoice retrospectively
• Confirmation statements filed through Companies House WebFiling are typically processed immediately; paper CS01 filings can take several weeks
• Failure to file within 14 days of the deadline is a criminal offence for the company and its officers — penalties include fines and ultimately strike-off
• Companies House has been increasingly active in using its powers to strike off companies that fail to file confirmation statements, with an accelerated procedure for apparent dormant or abandoned companies

Impact of Economic Crime Reforms on CSP Workload

ECCTA 2023 and associated reforms significantly increase the compliance burden for CSPs managing UK company portfolios. The combination of identity verification requirements, registered email obligations, ACSP registration, and enhanced PSC register expectations adds meaningful additional work per entity per year. CSPs should factor this increased cost into their fee structures for UK company administration — and should invest in technology that automates as much of this process as possible.

The UK confirmation statement process has never been static, and ECCTA 2023 represents the most significant evolution since the introduction of the PSC register in 2016. CSPs that stay ahead of these changes, operationalise them through systematic processes, and communicate clearly with clients will maintain their compliance position — and their professional credibility — in an increasingly scrutinised environment.