Overview
For additional guidance, please refer to Steptoe's COVID-19 Resource Center.
Companies House announced certain changes during April 2020 to the company filing regime to lend support to companies as they deal with the impact of the COVID-19 outbreak. These build upon on the changes previously introduced by Companies House in March 2020 granting companies affected by the coronavirus outbreak a three-month extension period to file its year-end accounts.
Changes to Strike-off Policy and Late Filing Penalties
On April 16, 2020, Companies House announced additional temporary changes to its company strike-off policy and approach to late filing penalties.
The new measures include:
- Pausing the strike-off process to prevent companies from being dissolved. When a company makes a voluntary application for strike-off, Companies House will publish a notice in the Gazette in accordance with its usual process, but will suspend any further action to dissolve the company in order to protect those who may wish to object to the company being struck off;
- Companies House continuing to write to companies that have failed to file their annual accounts or confirmation statement however, it will not publish a Gazette notice indicating its intention to strike-off the company. These changes do not apply to businesses being dissolved under an insolvency procedure, such as administration or liquidation; and
- Treating late filing penalty appeals sympathetically where the late delivery was caused by the COVID-19 outbreak. Companies House also states that it will provide a break for companies to pay late filing penalties, as well as offering additional support with payment plans for late filing penalties. These changes build on the previous measures announced in March 2020, under which companies can apply for an immediate and automatic three-month extension for filing their annual accounts where they are affected by COVID-19 issues.
Companies House highlights that these policy changes are temporary and will be kept under review and amended as necessary in light of the ongoing COVID-19 outbreak. The Secretary of State for Business, Energy and Industrial Strategy stated that Companies House will continue to monitor what companies are filing and will provide further extensions if needed.
Emergency Filing Service
On April 27, 2020, Companies House announced that its emergency filing service is now available to enable a selection of registrar's powers forms to be uploaded and submitted online.
The service can be used to:
- Apply for rectification by the registrar of companies (Form RP02A).
- Apply for rectification of a change of registered address (Form RP02B).
- Object to a request to rectify the register (Form RP03).
- Apply to remove material about a director (Form RP06).
- Apply to change a company's disputed registered office address (RP07).
- Correct a director's date of birth (Form RPCH01).
Companies House states that the service will be expanded to include more document types and features, such as acknowledgments and payments. In the meantime, it will only be available for a selection of paper forms that do not already have an online option. Use of the emergency filing service offers a quick and simple way for companies to file certain documents thereby reducing the delay in processing documents.
