A dissolved company is no longer your client: it has stopped existing as a legal person, so there is nothing to onboard, no customer due diligence to refresh and no risk class to set. What remains is the file you already hold. Close it on a dated register finding, record when the business relationship ended, and keep the records for five years from the date you knew it had ended. EntityWatch reads the register, quotes its wording and lets you sign the file closed in a few minutes, and it is free for up to five companies.
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Illustration: example data, not a real client. The right-hand panel is the EntityWatch dashboard, showing a company that Companies House records as dissolved.
By Martin Nymann, AddonNordic ApS, the company behind EntityWatch. Updated 5 October 2026.
- Is a dissolved company still your client?
- When does the five-year retention period start?
- What should the closing note record?
- What if the company is restored to the register?
- How do you find out in time that a client has been dissolved?
- What does EntityWatch do with a dissolved company?
- Frequently asked questions
Is a dissolved company still your client?
No. Once a company is dissolved it no longer exists, so there is no customer and no business relationship left to continue.
Under the Companies Act 2006, section 1012, everything the company owned at dissolution passes to the Crown as bona vacantia. The directors no longer act for it, and nobody can instruct you in its name. The Money Laundering Regulations 2017, regulation 27 ties customer due diligence to establishing a business relationship or carrying out a transaction, and neither can happen with a company that has ceased to exist.
That changes the question your supervisor will ask. It is no longer “what risk does this client present?” but “did you notice, when did you notice, and what did you do with the file?”. The answer belongs in a closing note, not in a risk assessment.
When does the five-year retention period start?
On the date you knew, or had reasonable grounds to believe, that the business relationship had come to an end. That is not always the date of dissolution.
Regulation 40(3)(b) starts the five-year clock from that knowledge, for both your due diligence records and the records of transactions within the relationship. Records of transactions within the relationship need not be kept for more than ten years (regulation 40(4)). Once the period has run, regulation 40(5) requires you to delete personal data obtained for anti-money-laundering purposes, unless another law, court proceedings or the data subject’s consent says otherwise.
So if a client was struck off in October 2022 and you only read the register in March 2026, write down both dates. The date you read the register is the evidence of when you knew.
| Event | What to record | Where it comes from |
|---|---|---|
| Dissolution | The register’s own wording and date | Companies House entry for the company |
| You learn of it | The date you read the register, and who read it | Your file note |
| Relationship ends | The date and the reason: dissolution | Your file note, signed |
| Retention ends | Five years after the date you learned of it | Regulation 40(3) |
| Deletion | The date personal data is deleted, or why it is kept | Regulation 40(5) |
What should the closing note record?
A short, signed note that a reviewer can check against the register without asking you anything. In practice:
- The register finding. The company’s name and number, the status as Companies House states it (“Dissolved on …”), and a link to the entry.
- The date you read it, and who read it. This is what starts the retention clock.
- That the relationship has ended, and why. One sentence: the customer has been dissolved and no longer exists.
- Work that was still in hand. A final return, fees owed, a request from a liquidator or a former director. Take instructions only from whoever now holds authority, and verify that authority from the filing that gave it to them, not from the company.
- Retention and deletion. The date the five-year period ends, and the date personal data will be deleted under regulation 40(5).
- Anything that looked wrong. If the dissolution raised a concern, for example a company struck off with money still moving through it, record that your nominated officer considered it. Whether a report is made is their decision, in their own name.
The client file guide covers what the rest of the file should already hold, and what your supervisor looks at in a client file covers how a reviewer reads it.
What if the company is restored to the register?
Treat it as a company you have to look at again before you act for it. Restoration is possible for years after dissolution.
A former director or member can apply to the registrar for administrative restoration within six years of dissolution (section 1024), and a court application is generally possible within the same six years (section 1030). Once restored, the company is deemed to have continued in existence as if it had never been dissolved (section 1028).
The people behind it may have changed in the meantime. Before you take instructions again, read the register afresh, check who the directors and people with significant control are now, and update the file. Regulation 28(11)(b) requires you to keep due diligence information up to date, and a restored company is the clearest case for it. This is also why you keep the closed file for the full five years rather than deleting it on dissolution.
How do you find out in time that a client has been dissolved?
By checking the register as part of ongoing monitoring, not by waiting for the next engagement letter. Regulation 28(11) requires ongoing monitoring of every business relationship.
When Companies House strikes off a company it believes is no longer trading, it first publishes a notice in The Gazette, and the company is dissolved when the final striking-off notice is published (section 1000). A practice that only looks at a client’s register entry once a year can miss the whole sequence. The ongoing monitoring guide sets out what counts as evidence that you are watching.
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What does EntityWatch do with a dissolved company?
It reads the register, says plainly that there is no customer, and lets you close the file on that finding. Here is what the dashboard showed for a company Companies House records as dissolved:
- The register’s wording, dated. “Dissolved on 14 October 2022 (Companies House, read 2 October 2026)”, with a link to the register entry.
- No onboarding. The note states that the company is no longer a legal person, that there is no business relationship to establish or continue, and that the file closes on the register entry rather than on a risk class.
- Screening of every name the register publishes. The current name, five former names and the one officer listed, against the UN, EU, UK (FCDO) and US OFAC lists and PEP data.
- What to do with work in hand. Take it up with whoever now holds authority, verified from the filing that gave it to them.
- A signed close. “Close the file on the register finding” records the register’s wording, the date it was read and your name in the audit trail, which is the evidence a reviewer asks for.
For clients that are still trading, EntityWatch watches the Companies House entry and tells you when the status changes, including insolvency and dissolution. See how it works and what each plan includes.
Frequently asked questions
Do I still need customer due diligence for a dissolved company?
No. A dissolved company no longer exists, so there is no business relationship to apply due diligence to. You record the register finding and close the file.
How long must I keep the file of a dissolved client?
Five years from the date you knew, or had reasonable grounds to believe, the relationship had ended, under regulation 40(3) of the Money Laundering Regulations 2017. Records of transactions within the relationship need not be kept for more than ten years.
Can a former director instruct me on behalf of a dissolved company?
Not in the company’s name, because it no longer exists. If they apply to restore it, read the register again and update your due diligence before you act.
What if the company is restored after I closed the file?
It is deemed never to have been dissolved. Re-read the register, check the current directors and people with significant control, and update the file before you take instructions.
Get started free: close your first file on the register finding
This article explains the rules in general terms and is not legal advice.
This content was generated with artificial intelligence.