A change at Companies House should trigger a review of the client file when it can change who owns or runs the client, or whether the client is still trading: a new or ceased person with significant control, a director appointed or removed, overdue filings, a strike-off notice, or a move into liquidation. A name change or a new registered office rarely changes the risk on its own, but it still belongs in the file with the date you saw it. EntityWatch re-reads Companies House for each client you monitor and holds today’s directors and owners with the dates the register gives. It is free for up to five companies.
Get started free: write your first client note
By Martin Nymann, AddonNordic ApS, the company behind EntityWatch. Updated 19 October 2026.
- What do the regulations say should trigger a review?
- Which Companies House changes should trigger a review?
- Which changes can wait for the next scheduled review?
- What does the register not tell you?
- What should the file record when a trigger fires?
- How does EntityWatch help?
- Frequently asked questions
What do the regulations say should trigger a review?
A change in the client’s circumstances that matters to your risk assessment is itself a reason to apply customer due diligence again. Regulation 27(8)(b) of the Money Laundering Regulations 2017 requires CDD measures “when the relevant person becomes aware that the circumstances of an existing customer relevant to its risk assessment for that customer have changed”. Regulation 27(8)(a) adds reviews “at other appropriate times” on a risk-based approach, which is your scheduled review.
Regulation 27(9) lists what you must take into account when deciding when to act. Four points:
- any indication that the identity of the customer, or of the customer’s beneficial owner, has changed;
- transactions that are not reasonably consistent with what you know about the customer;
- a change in the purpose or intended nature of your relationship with the customer;
- any other matter that might affect your assessment of the risk.
The first point is the one the public register speaks to directly. The other three come from your own work with the client. Regulation 28(11) then requires ongoing monitoring, including reviews of existing records and keeping the CDD documents and information up to date. If you want the wider picture of scheduled and event-driven reviews, start with ongoing monitoring of clients: what counts as evidence.
Which Companies House changes should trigger a review?
The changes that can alter who owns the client, who runs it, or whether it is still operating. Each one appears on the company’s filing history at Companies House, usually under a form code.
| Change on the register | Typical filing | Why it matters | What to do |
|---|---|---|---|
| New person with significant control, or one ceases | PSC01–PSC03 (notified), PSC07 (ceased) | An indication that the beneficial owner has changed, the first point in regulation 27(9) | Identify and verify the new beneficial owner, screen the name, and reassess the risk |
| Change to a PSC’s details or nature of control | PSC04, PSC05 | The size or kind of control may have crossed or dropped below the 25% threshold | Read the new statement of control and record whether the beneficial owner is still the same person |
| Director appointed or terminated | AP01, TM01 | A new person runs the client, or the person you dealt with has gone | Screen the new director and record whether the change affects who controls the company |
| Accounts or confirmation statement overdue | shown as overdue on the company overview | The company may not be operating, and it is the usual path to a strike-off | Ask the client why and record the answer and the date |
| First Gazette notice for compulsory strike-off | GAZ1 | The registrar may strike the company off two months after the notice | Decide whether the engagement continues and record the decision |
| Application to strike off, liquidation or administration | DS01, liquidation and administration filings | The status of the client is changing | Reassess the relationship and follow your process for a dissolved client company |
The PSC row is the one most likely to change the answer in your file. A new parent company means the ownership chain has to be traced again from the top, as set out in tracing a client’s owners through a holding company. Companies House guidance for people with significant control says the company must tell Companies House about a change to PSC information within 14 days of confirming the change, so the register can trail the real change by a few weeks.
The strike-off row has a fixed timetable. Under section 1000 of the Companies Act 2006, when the registrar believes a company is not carrying on business, it writes twice and can then publish a Gazette notice that the company will be struck off and dissolved two months from the date of the notice unless cause is shown.
Get started free: see the register picture for one of your clients
Which changes can wait for the next scheduled review?
Changes that do not alter ownership, control or status. Record them when you see them, and look at them properly at the next scheduled review unless they come together with something else.
- Change of company name (NM01). Update the file and screen the new name. A name change at the same time as a new PSC deserves a question to the client.
- New registered office address (AD01). Usually administrative. Note it, and ask if it coincides with a change of owner or a move to an address that has no link to the business.
- Change to a director’s details (CH01). A new service address or a corrected date is housekeeping. Keep the file in line with the register.
- A confirmation statement filed on time (CS01). Confirms the information on the register. Read it for any ownership statement that differs from what you hold.
A combination is what turns a routine change into a trigger. A new name, a new registered office and a new PSC in the same month describe a different business from the one you onboarded.
What does the register not tell you?
It does not tell you about transactions, the purpose of the relationship, or anything the company has not filed. Three of the four points in regulation 27(9) come from your own work: payments that do not fit what you know, a client who asks you for a different kind of service, or news about the client that the register does not carry.
Regulation 28(9) also says you do not meet the beneficial ownership duty by relying only on what is filed at Companies House. Treat the register as the trigger and the starting point, then compare it with what the client tells you, and record any difference.
What should the file record when a trigger fires?
The change, the date you saw it, what you did, and the decision, signed by the person who made it. A short record is enough when it is complete:
- the change, quoted from the register, with the filing date and a link to the filing;
- the date you became aware of it;
- the checks you carried out, such as screening a new name or tracing a new parent company;
- whether the risk rating changed, and why;
- who reviewed it and on what date.
That is the same record an inspector asks for when they test whether your monitoring works. How to write the decision itself is covered in how to record an AML decision so it holds up at inspection, and what to do with a possible hit on a new name is in a client is a possible sanctions match.
How does EntityWatch help?
It reads the register for you, so the trigger is not left to someone remembering to look. EntityWatch re-reads Companies House for each client you monitor, holds today’s directors and people with significant control with the dates the register gives, and screens those names against the UN, EU, UK and OFAC lists. You review, decide and approve; the client note keeps the source and the date for each fact. How it works shows the steps, and pricing shows the plans, starting free for five companies.
Frequently asked questions
Does every Companies House filing mean I have to redo CDD?
No. Regulation 27(8)(b) applies when a change is relevant to your risk assessment. A change of owner, control or status usually is. A new registered office or an updated service address usually is not, but it should still be noted in the file.
Is a change of director a change of beneficial owner?
Not necessarily. A director runs the company; a beneficial owner owns or controls more than 25% or otherwise controls it. Screen the new director and check the PSC register to see whether ownership has changed as well.
How quickly does a change reach Companies House?
Companies House guidance says a company must tell it about a change to PSC information within 14 days of confirming the change. The register can therefore lag the real change, which is one reason regulation 28(9) says the register alone is not enough.
What should I do when a client receives a strike-off notice?
Ask the client whether the company is still trading and record the answer. Under section 1000 of the Companies Act 2006 the company can be struck off and dissolved two months after the Gazette notice, so decide whether the engagement continues and record that decision.
To watch the register for your own clients, get started free with five companies and write your first client note.
This article is general information, not legal advice.
This content was generated with artificial intelligence.