Economic Crime & Corporate Transparency Act 2023 (ECCTA) – New Template Documents for Charitable Company Trustees

ECCTA and Charitable Companies Limited by Guarantee 

The Economic Crime & Corporate Transparency Act 2023 (ECCTA) is being progressively brought into effect over the period 2024-6. 

The next date for implementation of further provisions of the ECCTA will be 18 November 2025. That implementation will trigger a range of obligations affecting legal entities set up in the form of companies.  

Those obligations will apply to all charitable companies limited by guarantee (“CCLBGs”) as well as to other companies.  

These obligations will not however apply to other forms of charitable organization or their trustees. For example, it will not apply to any charity which is set up in the form of a Charitable Incorporated Organisation (CIO), an Unincorporated Association or a Charitable Trust. 

New Obligations for CCLBG’s: 

• Identity verification by directors of a CCLBG (i.e. the trustees of a charity which is a CCLBG) and the secretary of a CCLBG. (This will be compulsory from 18 November 2025). 
• maintenance by a CCLBG of accurate registers of its directors and members. Under the ECCTA, the register of directors must be held at Companies House (and no longer has to be held by the CCLBG), and the register of members must be held by the CCLBG. 
• disclosure of the beneficial ownership of the CCLBG. Though a CCLBG may not have a "beneficial owner" in the traditional sense, transparency on individuals controlling or influencing it is still required. 
• further restrictions on choice/use of the CCLBG’s name/s. 
• requirement for a CCLBG to register an “appropriate” registered (official) address and an “appropriate” email address. 
• new requirements for a CCLBG’s financial statements that must be filed with Companies House. 
• additional transparency requirements when incorporating a CCLBG.  
• new enforcement powers for Companies House. 

In view of the increased burden that these new obligations impose on CCLBGs, some CCLBGs may wish to consider converting their charities into the form of CIOs since fewer and less onerous requirements apply to CIOs and their trustees than to CCLBGS and their trustees/members. 

Templates Covering these New Requirements 

Further details of these new requirements are set out in the new template documents. Use of these new templates should assist you to understand and implement the important new obligations affecting CCLBGs and their trustees. 

If you are a trustee or secretary of an existing CCLBG (or are otherwise involved in its governance) or you are planning to set up a new CCLBG, we recommend that you download these new documents.  

You might also find it useful to read our recent Newsletter here about the provisions of the ECCTA being implemented on 18 November 2025. It applies to charitable companies (CCLBGs) as well as to commercial companies.