July 27, 2026 What ECCTA implementation to date tells us about presenter restrictions
Presenter restrictions are not arriving in a vacuum. The first phase of ECCTA implementation already shows how Companies House is likely to use its new powers: more challenge, more attribution and more scrutiny of the evidence behind filings.
That matters for law firms because presenter restrictions will not just be another filing rule. They will affect who can submit information, what checks need to sit behind that submission and how firms evidence the judgement they have made.
This article looks at three early lessons from ECCTA implementation: Companies House is prepared to act at scale, filings are becoming easier to trace back to people and firms, and a small number of edge cases could create disproportionate operational friction.
Enforcement is moving from words to action
Companies House is no longer waiting for problems to be corrected. It is using its powers at scale, which matters because presenter restrictions will operate in a regime already prepared to challenge filings.
The third ECCTA progress report shows the scale of the change. In the year to 31 March 2026, Companies House used its new powers to address compliance issues involving around 158,000 companies. During the same period it:
- removed 151,000 registered office addresses linked to address misuse;
- removed 119,000 officer addresses and 95,200 PSC addresses;
- redacted 77,900 incorporation documents and removed 22,900 documents from the register;
- annotated company records, issued penalty warnings and took enforcement action in relation to compliance failures, including missing identity verification statements; and
- suspended 74 authorised corporate service providers (ACSPs).
Presenter restrictions will not land in a passive filing system. They will land in one where poor-quality or questionable information is more likely to be queried, annotated or escalated.
Filings are becoming permanently tethered to people and firms
Challenge and accountability are developing together. As Companies House becomes more willing to question filings, the regime becomes better at identifying who sits behind them.
Identity verification is part of that, but it is not the whole story. The authorised corporate service provider regime, registered email addresses and stronger Companies House scrutiny all point in the same direction: filings are becoming easier to connect to the people, firms and evidence behind them.
The filing system is no longer just a record of company information. Increasingly, it also creates a trail showing who verified, who presented information and what evidence or judgement sat behind the submission.
The reputational dimension is already visible. Elemental has started to receive more media enquiries around Companies House filings. That suggests scrutiny is beginning to move beyond the company itself towards the filing record, the judgement behind it and the professional involvement attached to it.
Presenter restrictions will take that further by controlling who can access the filing channel and making the link between the filing and the person, process or professional judgement behind it harder to avoid.
The hard cases will drain time
The burden will be uneven. Most filings will likely be straightforward. The resource drain will come from edge cases such as overseas documents, mismatched personal details, hard-to-reach directors, unclear authority, historic data issues or uncertainty over what evidence is sufficient.
For law firms and advisers, that is the commercial point. A small number of awkward cases can consume a disproportionate amount of time, judgement and senior attention. The legal work may be complete and the approvals in place, yet one unresolved verification point, evidence gap or authorisation issue can still delay completion.
The same pattern is likely under presenter restrictions. Entity data, authority to file, verification status, supporting evidence and record keeping will need to be managed before the filing moment, not discovered at it. The risk is not that every filing becomes difficult, but that a few become disproportionately disruptive.
Market practice will move before the law feels settled
The other lesson from IDV is that firms often have to make practical decisions before the law feels settled. History suggests detailed guidance can arrive late, and where professional bodies do issue guidance, it is usually cautious. The Law Society’s recent IDV guidance, discussed separately here, is a good example: it points firms towards clear evidence of what was checked and, in some cases, screenshots to evidence the verification position at the relevant time.
That is why “reasonable excuse” matters in practice. If a filing is later challenged, the question will not be answered by intention alone. Firms will need to show what position they took, why it was reasonable at the time and what evidence supported it.
This is a governance challenge as much as a legal one. Those building processes, systems and client workflows for presenter restrictions will need to start now, before every practical question has been answered. Elemental is going through that exercise as part of its client-facing software build: making defensible assumptions, deciding what evidence should be captured and building escalation points before the regime is fully settled.
Why firms should prepare now
Presenter restrictions are where these lessons start to matter. They are the point at which early enforcement activity, attribution, evidence standards and operational pressure begin to converge.
Firms will need to prepare before every detail is settled. The clues are already there: Companies House is willing to challenge filings, professional guidance is likely to remain cautious, evidence expectations are rising, and awkward cases can create a disproportionate amount of work.
That is the value of looking back. Elemental is already applying these lessons as part of its new solution to support clients with Companies House filings at scale once the new rules come into force. The sequencing may move, but the direction is clear: future filings will increasingly carry a person, a process and a professional judgement.