A New Dawn of Transparency: Why ECCTA Changes Coming Tomorrow Will Reshape Property Due Diligence
By Phil Cotter
UK – 19 November 2025:
For years, the UK operated a corporate registry system based largely on trust. This vulnerability allowed shell companies, fraudulent names, and opaque ownership structures to flourish, enabling billions in illicit funds to be laundered through UK real estate. The message from the government and regulators is now crystal clear: Trust is out. Verification is in.
Estate agents, lettings agencies, and property developers must immediately recognise that the era of passive compliance is over. The November changes don't just affect company directors; they fundamentally change how the integrity of every property-holding entity must be assessed.
The Seismic Shift: Mandatory Identity Verification
The most immediate and far-reaching change is the introduction of mandatory identity verification (ID-V) for all individuals involved in UK corporate life.
ECCTA effectively turns Companies House from a passive records office into an active gatekeeper with enhanced enforcement powers to issue fines that hit companies hard, rather than just a “slap on the wrist”.
Who Must Verify and When:
- New Directors and People with Significant Control (PSCs): Any individual appointed as a director or PSC must verify their identity before their appointment is registered or within a very tight timeframe thereafter. They cannot act until ID-V is complete.
- Existing Directors and PSCs: A transitional period will begin, requiring all existing directors and PSCs to verify their identity. Non-compliance is not an administrative oversight; it can result in criminal penalties, public annotation of "unverified" status on the register, and even disqualification from acting as a director.
This shift has profound implications for every property transaction involving a corporate entity.
This Is Not Just a 'Big Business' Problem
Some smaller agencies may assume ECCTA only targets the complex, multi-layered structures associated with international investors or the high-value commercial market. This is a dangerous misconception.
ECCTA applies to all UK companies.
Whether you are selling a £150,000 terrace or a £15 million penthouse, if the buyer is a standard UK Limited Company (Ltd), an LLP, or a trust using an underlying corporate structure, the new identity verification rules apply to their directors and People with Significant Control.
- Local High Street Impact: Many local businesses, from builders and developers to convenience store owners, hold assets through small, regional companies. If the directors of those companies have not completed the mandatory ID-V process, they will be out of compliance, potentially delaying or even invalidating a sale.
- Risk of Transaction Failure: Estate agents are the first line of defence. If you accept instructions or proceed with a transaction involving an unverified company, you are exposed. The integrity of the UK corporate register is now being enforced, and the property sector is expected to reflect that enhanced transparency in its own due diligence. This is a fundamental layer of risk assessment that is now mandatory for every size of agency.
Why Now?
The government’s decision to pursue these rigorous changes is driven by clear and persistent threats detailed in the National Risk Assessment (NRA) and historical failures highlighted by the FATF Mutual Evaluation Report.
The 2018 FATF report identified the inconsistent supervision of non-financial sectors, including estate agents, as a primary weakness. Despite the introduction of the Office for Professional Body AML Supervision (OPBAS), the 2025 NRA confirmed that the property sector, along with legal and accountancy services, remains a high-risk area highly susceptible to exploitation by criminals.
The NRA specifically flags that money laundering threats driven by Fraud, Sanctions Evasion, and Cybercrime are persistent, with property and cryptoassets being the most exploited typologies.
The regulatory response has been emphatic: where the old fragmented system failed, the new centralised system, powered by mandatory ID-V and strengthened by the Economic Crime Acts, must succeed. This regulatory tightening validates the government's decision to move to the direct, rigorous enforcement of the FCA—a move that will invariably raise compliance expectations for all adjacent high-risk sectors, including property.
Your Compliance Safety Net: The SmartSearch Solution
The deadline to comply was November 18th, but the transitional period for existing directors means the challenge of verification will continue for the next 12 months. Businesses must invest in technology that not only meets current AML rules but is ready for this new ECCTA reality.
Your anti-money laundering (AML) checks must go beyond simple documentation. If your client is a corporate entity, you must demand assurance that its directors and PSCs are verified. This is where a fully integrated, multi-layered electronic verification (EV) platform is no longer optional—it is essential.
SmartSearch is ready to help you navigate ECCTA compliance immediately:
- Seamless Companies House Integration: Our system can instantly cross-reference your client's directors and PSCs against the newly enhanced Companies House data, quickly verifying corporate identity and ownership structure.
- Triple-Bureau Verification: We provide full compliance in a single check: verifying the individual’s identity, performing Politically Exposed Person (PEP) checks, and conducting Sanctions checks, all in one platform.
- UBO Mapping for Complex Deals: Our platform maps complex ownership structures instantly, ensuring you can identify and verify the Ultimate Beneficial Owner, regardless of the complexity of the company, LLP, or trust involved in the property purchase.
- Audit-Ready Digital Record: Every check produces a complete, non-editable audit trail, demonstrating to HMRC or any future FCA supervisor that you have met your due diligence obligations using best-in-class methods and have acted upon the ECCTA verification mandate.
The ECCTA changes are not merely a regulatory hurdle; they are an invitation to the property sector to lead by example. By embracing the mandate for mandatory verification and the power of digital due diligence, estate agents can actively purge the market of illicit funds, protect their businesses from crippling fines, and—most importantly—rebuild public trust in the integrity of the UK property market.
The time to secure your compliance strategy is not next week, but now.
To learn more about how SmartSearch is helping its customers to comply with regulations, fight financial crime and grow their business with confidence, visit our website.
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