The Dynamic Duo: Companies House and the Insolvency Service Power Up

Readers may be aware that as well as creating new corporate fraud offences and amending the laws on corporate attribution, the Economic Crime and Corporate Transparency Act 2023 is significantly reshaping the UK economic crime enforcement landscape by empowering  Companies House as a frontline regulator and intelligence partner to work hand in hand with the Insolvency Service in relation to enforcement.

This change has been heralded as the largest corporate governance reform in over a century, and one which carries significant implications and heightened expectations on boards and governance professionals.

On 16 June 2025, the Department for Business and Trade published its Second Progress Report into Parts 1-3 of the Economic Crime and Corporate Transparency Act 2023 (ECCTA) (the Report), which sets out the “significant progress” made in the last 12 months.

Progress milestones

The Report sets out that Companies House’s Intelligence Hub has expanded its capacity, making use of new data-sharing powers. Over the past year, it is reported that it has made c.600 intelligence referrals to partners such as the NCA, HMRC and the Insolvency Service; embedded intelligence officers within key partner agencies and engaged in collaborative threat analysis and joint operations.

The Insolvency Service is identified as a key strategic partner, furthering its long history of working with Companies House.   A new Insolvency Service Intelligence cell has begun to investigate 138 referrals from Companies House.

In addition, funding from the Economic Crime Levy and Companies House fees has already  enabled the Insolvency Service to investigate and prosecute cases under the Insolvency Act, Companies Act and Fraud Act.  Accomplishments have included director disqualifications, winding-up petitions, prosecutions, account freezing and asset forfeiture actions.

Recent enforcement activities include:

• Raids at 16 sites involving over 30 entities tied to 30,000–50,000 shell companies, with proceedings commenced to remove 10,000 of these companies from the register.
• Identification of £50 million in UK property related companies linked to criminal ownership under asset recovery investigation.
• Investigations into over 100,000 shell companies involved in FX and gambling fraud, crypto scams, and cybercrime.
• Ongoing action against directors for breaching disqualification orders.
• Companies House flagging 26 dormant companies with 1,984 entities registered at the same address.  Initial inquiries revealed suspected fraud, tax evasion and money laundering.
• 786 fake Companies mimicking real restaurant brands; 2,895 fraudulent appointments and 965 companies removed from the register.
• Europol Asset Sprint: Companies House joined 43 agencies across 28 countries in a joint asset seizure campaign.

Governance issues

Boards should view ECCTA compliance as part of broader ESG and corporate responsibility strategy. Disclosures to Companies House will increasingly affect external stakeholder trust and reputational risk.  A review should be undertaken into filings to ensure that contents are accurate, verifiable, and timely. Governance professionals should establish or reinforce internal checks before submitting data to Companies House, especially around director appointments, registered office details, and People with Significant Control (PSC) information.

Boards must be aware that Companies House and the Insolvency Service are empowered. with inter-agency intelligence flows increasing the likelihood of scrutiny if governance structures or behaviours fall short. Disqualified directors, opaque PSC arrangements, and repeated use of dissolved companies are high-risk red flags which are likely to be investigated.

How Gherson can assist

Gherson’s regulatory, white-collar and investigations team are highly experienced in providing assistance with corporate governance and defence matters.  If you require assistance with filing or correcting information at Companies House, or find yourself the subject of an investigation by the Insolvency Service our experts can help.

If you have any questions arising from this blog, please do not hesitate to contact us for advice; send us an email at enquiries@gherson.co.uk alternatively, follow us on X, Facebook, or LinkedIn to stay up-to-date.