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Before the Lender Asks: A Six-Point Companies House Hygiene Audit for 2026

Compliance Bureau
Before the Lender Asks: A Six-Point Companies House Hygiene Audit for 2026

Photo: Stefanik, CC0, via Wikimedia Commons

Companies House filings are often treated as back-office administration. They become material when a lender, acquirer, insurer or investigator asks a simple question and the answer does not match the public record. Register hygiene is preventive work: it reduces the chance that a historical error becomes a director-level problem during a transaction or inquiry.

The Economic Crime and Corporate Transparency Act 2023 changed the operating environment. Identity verification for directors and people with significant control has moved from a voluntary step to a routine part of filing and compliance. In 2026, good practice means treating the statutory registers, confirmation statement and identity verification evidence as a single paper trail rather than separate chores.

Why registers matter more than they appear

A company's statutory registers are the authoritative internal record of members, directors, secretaries, people with significant control and charges. Companies House holds a public record that should mirror them. When the two diverge, the company may still be legally correct internally, but the public record creates friction. A lender may pause drawdown. An acquirer may require a rectification deed. A director may face questions about a resignation that was never filed.

The risk is not only regulatory. Inconsistent filings are a fraud vector. A changed registered office, a new director appointment or a PSC update that is not properly evidenced can be exploited by someone seeking to divert correspondence or misrepresent control.

Six-point audit

  1. Reconcile the statutory registers to the public record. Check the register of members against the confirmation statement, the register of directors against appointments and resignations, the PSC register against filed PSC information, and the register of charges against filed charges. Record every difference, even if it is cosmetic.

  2. Test the confirmation statement for consistency. The confirmation statement confirms that the company has delivered required information and confirms its registered office, principal business activity, statement of capital, shareholders and PSCs. Common errors include an outdated SIC code, a shareholder list that does not reflect a transfer, and a PSC entry that still names a former controller.

  3. Review PSC records and nature of control. For each PSC, confirm the name, service address, date of birth month and year, nationality, country of residence and the nature of control. Check that the stated control band still matches the shareholding or voting rights. If a PSC has changed, ensure the update was filed promptly and the register was updated on the same evidence.

  4. Assemble identity verification evidence. Since the identity verification requirements took effect, directors and PSCs need a verifiable identity trail. Keep the date of verification, the method used, the identity document reference and the confirmation received. Do not rely on a colleague's memory or a screenshot without context. If a director was verified through an authorised agent, keep the agent's confirmation.

  5. Audit event-driven filings. Dividends, share allotments, transfers, director changes, registered office changes and charge creations all generate filing obligations. Compare board minutes and statutory registers to the Companies House filing history. A missing filing is easier to correct before a lender's due diligence than after.

  6. Create a remediation log. For every discrepancy, record what was found, when it was found, who reviewed it, what was filed or corrected, and what evidence supports the correction. The log is the difference between a company that made an error and a company that cannot explain its records.

Common mistakes and what to fix first

The most common mistakes are dull ones: a director resigned but the filing was never made; a share transfer was recorded in the register but not reflected in the confirmation statement; a PSC's control band was not updated after a rights issue; a registered office changed but correspondence was not redirected. Fix the items that affect control, ownership or the ability to receive official correspondence first. Then correct presentational issues such as SIC codes and business activity descriptions.

Do not backdate documents. If a filing was missed, correct it now and explain the sequence in the remediation log. Backdating creates a second, more serious problem.

Handling historic errors before they surface

If an error is historic, take advice on whether a rectification filing, a correction of the register or a court order is appropriate. The practical steps are usually the same: gather the underlying documents, obtain board approval for the correction, file promptly, update the statutory registers, and keep a clear audit trail. If the error affects a PSC or director, consider whether a separate notification is required.

In a transaction, disclose the issue early with the remediation evidence. A lender is more likely to accept a corrected discrepancy with a clear paper trail than an unexplained gap discovered late in diligence.

What good looks like

Good register hygiene is not a one-off spring clean. It is a quarterly routine: a named owner, a reconciliation checklist, a filing calendar and a remediation log. The public record should be boring, consistent and current. That is the quiet protection it offers directors: when someone asks the awkward question, the answer is already documented.

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