Successive legal changes have gradually increased the ability of individuals to prevent residential address information from being publicly available at the UK companies registry, Companies House. However, since Companies House records became free to access in June 2015, the UK government has received an increasing number of complaints that the continued availability of historic residential addresses has contributed to identity theft and instances of personal harassment.
The UK government has therefore introduced new rules to make it easier for individuals to apply for the suppression of historic residential address information on the public register – it is no longer necessary to demonstrate a serious risk of violence or intimidation in order to do so. At the same time, it has revoked rules preventing the removal of pre-2003 data still available at Companies House.
Background: the changing requirements for the disclosure of residential addresses of officers/directors and persons with significant control
The historic requirements for address disclosure and the suppression of that information can be summarised below.
The revised framework
The final Companies (Disclosure of Address) (Amendment) Regulations 2018 (the “2018 Regulations”) came into force at the end of April 2018. The principal changes introduced by the 2018 Regulations are that:
- directors and PSCs will no longer have to demonstrate a serious risk of violence or intimidation as part of the application for the removal of historic residential address information from the public register
- there is no longer a restriction preventing individuals from applying for removal of information where a residential address was placed on the register before 1 January 2003. This date was specified in the original legislation as before that date records were held in non-electronic format, and it was previously thought that removing that information could not be done without damaging other aspects of the public record.
Accordingly, address disclosure requirements (as modified by the 2018 Regulations) are now as follows:
What will be shown if the residential address is removed?
Where an applicant’s current address must be provided due to active directorship or as a PSC, this will be replaced by the designated service address. Where they are no longer appointed to a company, the information provided for a director’s address will be limited to the first half of the postcode.