Confirmation Statement vs Annual Return: What Changed?
For many UK limited companies and limited liability partnerships (LLPs), the confirmation statement has been a familiar filing requirement for nearly a decade, having replaced the old annual return in 2016. Yet despite this transition, one question continues to arise: what changed and why does it still matter today?
The annual return (Form AR01) was formally abolished on 30 June 2016 and replaced by the confirmation statement (Form CS01), introducing a more streamlined approach to maintaining company records. However, the evolution did not stop there. Recent reforms – particularly under the Economic Crime and Corporate Transparency Act 2023 (ECCTA) have significantly reshaped the compliance landscape.
This article explores the key differences between the annual return and the confirmation statement, outlines the latest regulatory developments, and explains what today’s rules mean for directors, company secretaries, and LLP members responsible for maintaining compliance.
What Was the Annual Return?
Until 30 June 2016, UK companies were required to file an Annual Return with Companies House (using form AR01). Every UK company and LLP had to file one each year, within 28 days of the made-up date. The key point is what ‘filing’ meant: you had to re-enter the company’s full registered details from scratch – office address, directors, secretaries, shareholders, share capital, SIC code, regardless of whether any of it had changed since the previous year.
Key features of the old Annual Return regime:
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Form used
AR01
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Filing Window
28 days after the made-up date (the annual snapshot date at which the company’s information had to be accurate)
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Online filing fee
£13 (£40 by post)
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Content
Full re-submission required each year - registered office, directors, secretaries, shareholders, share capital, and SIC codes, even if nothing had changed
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PSC information
Not required (the People with Significant Control regime did not exist until April 2016)
The Annual Return served its purpose of keeping the public register up to date, but it was paperwork-heavy and duplicative. The system effectively required companies to re-confirm the same information every twelve months, whether or not it remained accurate or had changed at all.
The Confirmation Statement: A Modern Approach
From 30 June 2016, the Annual Return was abolished and replaced by the Confirmation Statement under section 853A of the Companies Act 2006, as inserted by the Small Business, Enterprise and Employment Act 2015.
The core idea behind the switch was straightforward: instead of asking companies to re-file everything each year, ask them to check what is already on the register and confirm that it remains correct as at the confirmation date. Where there are no changes, the filing is little more than a review-and-confirm exercise.
Key features of the Confirmation Statement:
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Form used
CS01 (LL CS01 for LLPs)
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Filing Window
14 days after the end of the review period
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Review period
12 months beginning the day after the previous confirmation date, or the date of incorporation for a new company
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Filing fee from 1 February 2026)
£50 online / £110 by post
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Annual payment period
A single fee covers the 12-month period; additional CS01 filings within the same period do not incur further fees
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People with Significant Control (PSC)
The CS01 in 2016 required companies to disclose PSC information (those holding more than 25% of shares or voting rights), a requirement that did not exist under the annual return regime. Under the current framework, PSC information must be updated at Companies House as changes occur with the CS01 serving only to confirm that all PSC details already filed are accurate and complete. This approach has been reinforced by reforms under the Economic Crime and Corporate Transparency Act 2023, including mandatory identity verification and stricter enforcement.
Comparison: Confirmation Statement vs Annual Return
The two filings serve broadly the same purpose, but the mechanics, content obligations, and compliance stakes are materially different.
| Identifier | Annual Return (AR01) – Pre 30 June 2016 | Confirmation Statement (CS01) – Post 30 June 2016 |
|---|---|---|
| Form | AR01 | CS01 (LL CS01 for LLPs) |
| Filing window | 28 days after annual date | 14 days after the end of the review period |
| Core approach | Re-enter all company details in full every year | Review existing information and confirm accuracy; update only where necessary |
| Online fee | £13 | £50 (from 1 Feb 2026) |
| Paper fee | £40 | £110 (from 1 Feb 2026) |
| PSC disclosure | Not required | Required; must be kept up to date and confirmed on each CS01 |
| Lawful purpose statement | Not required | Required on every CS01 filed on or after 4 March 2024 |
| Registered email address | Not required | Required from 4 March 2024 |
| Identity verification of directors / PSCs | Not required | Began taking effect from 18 November 2025 for all directors and PSCs |
| Officer changes | Could be reported on the AR01 itself | Must be filed separately (e.g. TM01, AP01) before submitting CS01 |
| Applies to | All UK companies and LLPs | All UK companies and LLPs, including dormant entities |
What Must Now Be Confirmed and Why the Rules Have Changed
When filing a Confirmation Statement , companies must confirm that key information held by Companies House is accurate and up to date. Many of these requirements have evolved significantly in recent years following reforms introduced under the Economic Crime and Corporate Transparency Act 2023 (ECCTA).
The Act is designed to transform Companies House from a largely passive register into a more active regulator – one that verifies information, identifies inconsistencies, and supports enforcement against misuse of UK corporate structures.
Basic company information
Confirm the following details on the register are accurate before filing:
- Registered office address
- Directors and secretaries
- SIC codes describing the company's business activity
- Shareholder information and statement of capital
- People with Significant Control details (as already filed with Companies House)
Registered email address
Every company must provide a registered email address when filing its Confirmation Statement. This address is used by Companies House for official communications and is not visible to the public.
The address must be capable of bringing official correspondence to the attention of someone acting for the company. A dormant or unattended mailbox will not meet this requirement.
Lawful purpose statement
A statutory declaration confirming the company's intended future activities are lawful must be included on every CS01 filed on or after 4 March 2024. This applies to all companies and LLPs, including dormant ones.
This creates a clear, dated record of a director's confirmation of lawful intent — one that can be referenced in any later enforcement action or prosecution. Companies House also has new powers under ECCTA to query, reject, and remove information it considers false or suspicious.
Appropriate registered office
A company's registered office must now be an appropriate registered office — meaning an address where documents delivered by hand or by post would genuinely reach someone acting for the company, and where delivery can be acknowledged.
A PO Box address alone no longer meets this standard. Companies House has the power to change a registered office on the record if it considers the address inappropriate, without waiting for the company to act.
Identity verification of directors and PSCs
Identity verification requirements are now in effect, with phased compliance obligations for all directors and People with Significant Control.
- New appointments (from 18 Nov 2025): identity must be verified before the appointment can be registered.
- Existing directors (in post before 18 Nov 2025): must verify identity before the company's next annual confirmation statement, within a 12-month transition period — after which non-compliance becomes a criminal offence.
- PSCs who are also directors: must provide their personal code via the CS01 as director, and via a separate service within 14 days of the confirmation statement date as PSC.
- PSCs who are not directors: must submit their verification statement within the first 14 days of your birth month as shown on Companies House. For example, if your date of birth is 22 January, your 14-day window begins on 1 January.
- Get to know more about our confirmation statement filing service for SPVs
How to Complete Identity Verification
There are several ways to complete identity verification:
GOV.UK One Login
Fastest route, completed via the GOV.UK ID Check app using a biometric passport or driving licence, plus a facial recognition liveness check.
Free & fastestIn person at a Post Office
Alternative for individuals without compatible biometric ID or who cannot complete the digital verification process.
Walk-inVia an authorised ACSP
Companies House authorised agent (such as an accountant, solicitor, or formation agent) who can verify identities on behalf of individuals. This route is particularly useful for overseas directors or those unable to use UK digital ID services.
Agent-assistedPersonal code issued on verification
Once verified, each individual receives an 11-character personal code linked to their verified status. Companies and filing agents should retain this securely for future filings and compliance purposes.
X X X – X X X X X – X XWhat Can and Cannot Be Updated on the CS01
This is one of the most common sources of confusion among directors. The Confirmation Statement is not a general-purpose update form. It can only be used to change specific items. For everything else, a separate form must be filed first.
Items you can update directly on the CS01:
- SIC code (Standard Industrial Classification)
- Statement of capital
- Trading status of the company’s shares
- Shareholder information (names, holdings, share class)
Items that require a separate form, filed before the CS01:
- Registered office address: form AD01
- New director appointment: form AP01 (individuals) or AP02 (corporates)
- Director resignation or removal: form TM01
- Change to director’s details: form CH01 or CH02
- PSC registration, change, or cessation: forms PSC01 to PSC09 as applicable
- Registered email address: via the dedicated Companies House service (not on the CS01 itself)
The sequence matters. The CS01 confirms what is on the register as at the confirmation date. If a director resigned three months ago but form TM01 was never filed, the CS01 cannot be used to correct that oversight. The TM01 must be filed first, and only then does the CS01 confirm the updated position.
Confirmation Statement Filing Fees: Recent Changes and Current Rates
Companies House fees are set on a cost-recovery basis and may be subject to further change. As the scope of the Confirmation Statement has expanded and the infrastructure required to support identity verification and fraud enforcement has grown, the fees have risen sharply.
| Period | Online fee | Paper fee | Driver of change |
|---|---|---|---|
| Before 1 May 2024 Legacy rate | £13 | £40 | Legacy rate, unchanged for many years |
| 1 May 2024 – 31 Jan 2026 First uplift | £34 | £62 | ECCTA 2023 First fee uplift to fund Companies House reforms |
| From 1 February 2026 Current Second uplift | £50 | £110 | ECCTA 2023 Second uplift to fund identity verification infrastructure and fraud enforcement |
The confirmation statement fee operates on a 12-month payment period, which is separate from the review period. The fee is charged once per payment period; at the time the first confirmation statement is filed within that period. After this initial payment, the company can submit additional confirmation statements during the same period without incurring extra fees.
If a confirmation statement is submitted after the start of a new payment period, the applicable fee for that new period will be charged. As a result, the fee applied depends on when the statement is filed, rather than the period to which it relates.
Filing Deadlines and the Consequences of Getting It Wrong
The review period for a Confirmation Statement begins the day after the previous confirmation date and runs for 12 months. The statement must be filed within 14 days of the end of that review period. For a newly incorporated company, the first review period runs from and including the date of incorporation for 12 months, with the CS01 then due within the following 14 days.
Failure to file a Confirmation Statement is a criminal offence under section 853L of the Companies Act 2006. Unlike late accounts, which carry tiered civil penalties starting at £150, late or non-filing of a CS01 can result in:
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Prosecution of the company and its officers
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An unlimited fine on conviction for the company and its officers
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A criminal record for individual directors or secretaries found responsible
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Strike-off from the Companies House register, with the company's assets passing to the Crown as bona vacantia
Companies House has been strengthened under ECCTA with new powers to actively investigate, impose civil financial penalties as an alternative to prosecution, and strike off persistent non-compliers. This is a materially more active enforcement environment than existed under the old Annual Return regime.
Practical Compliance Steps
For directors and company secretaries managing Confirmation Statement obligations under the current regime, the following steps will keep filings on track and avoid enforcement action.
Know your confirmation date and deadline
Your confirmation date falls on the anniversary of your last CS01, or the incorporation date for a new company. Add 14 days to find your filing deadline. Diarise both dates well in advance.
Verify your identity before the CS01 is due
Complete identity verification via GOV.UK One Login if not already done. Store your personal code securely — Companies House does not routinely reissue it.
Confirm every director and PSC has also verified
If any director has not completed identity verification, the CS01 may be rejected. Check the status of all officers before the filing window opens, not on the day itself.
Review the live Companies House record
Log in and check the register for your company: registered office, registered email, all directors and PSCs, SIC codes, and share capital. Do not assume the record is correct.
File all change forms before the CS01
If anything needs updating — a director change, PSC change, or address change — file the relevant separate form first. The CS01 confirms what the register already shows; it cannot correct it retrospectively.
Include the lawful purpose declaration
Required on every CS01 filed from 4 March 2024. Not optional for any company, including dormant ones.
Budget for the current fee
Digital filing is £50. Paper is £110. The rate charged is the one in force on the date of submission.
Conclusion
The transition from the annual return to the confirmation statement in 2016 was not merely an administrative tweak but a cornerstone of modern UK company law. By replacing the static, repetitive AR01 with the dynamic, verification-based CS01, the government successfully balanced the competing needs of transparency and administrative ease.
The position has evolved significantly following the introduction of the Economic Crime and Corporate Transparency Act 2023. Identity verification, lawful purpose declarations, enhanced registered office and email requirements, and increased filing fees have all become integral to the confirmation statement framework.
As a result, the confirmation statement is no longer a routine administrative task that can be left until the last moment. It represents a key annual compliance checkpoint, ensuring that the company’s public records – including its officers, ownership structure, and registered details are accurate and up to date. Managing this process properly, and well in advance of the filing deadline, is now an essential part of good corporate governance for all UK limited companies and LLPs.
Susmita
Susmita is an ACCA finalist with a strong foundation in accounting, taxation, and financial reporting. She supports organisations in maintaining accurate, compliant financial records and delivering reliable insights for informed decision-making.