The confirmation statement deadline, worked out properly

What I did to myself in March

One statement sat on my desk in March with a July deadline, and I filed it because the file was open and I dislike open files. That is the whole of my reasoning and it was enough to move the next deadline by 4 months.

An early filing does not use up the current period. It starts a new one from the date you filed.

So a company whose review period ran to July now had one running to March, and the reminder I had written for June was pointing at a date that no longer existed. Nobody at the registry tells you this has happened. The register simply carries the new confirmation statement date and waits.

I had assumed early was free. It is not free, it is a rescheduling, and the confirmation statement deadline you memorised last year is not necessarily the one you have this year.

It still annoys me more than is reasonable, because the rule is published, it is one sentence long, and I had read the page at least a dozen times before the day I proved I had not understood it.

Somebody who files for a living should not need to learn that from experience, and I did.

How the clock is actually set

A company must review its records and file at least 1 confirmation statement every 12 months. The review period ends 12 months after the confirmation statement date on the last statement, or 12 months after incorporation when it is the first one.

The guidance states it in one line: "You must review your records and file at least one confirmation statement every 12 months."

After that period ends you have 14 days. Those 14 days are the entire margin you get.

That window does not stretch for weekends, for holidays, for a director who is travelling, or for verification that is still running. It is the shortest window on anything a UK company files, and it is attached to a date that most people cannot recite from memory.

The reliable way to find yours is to look the company up on the register rather than to trust a note you made a year ago, because the note was written before anybody filed anything early.

What it costs, in both directions

Online filing costs 50 pounds. One hundred and ten by post. The fee is charged once with the first statement in each 12 month payment period rather than every time you file.

Skipping it altogether is a different order of problem. GOV.UK puts it in one line: "You can be fined up to £5,000 and your company may be struck off if you do not file your confirmation statement."

Struck off is the part people skip past. It is not a penalty that sits on a ledger, it is the removal of the company from the register, and it happens to companies whose owners were busy rather than dishonest.

For contrast, the annual accounts deadline ltd companies work to carries a published ladder instead: 150 pounds up to 1 month late, 375 from 1 to 3 months, 750 from 3 to 6 months and 1,500 beyond that, doubling if the accounts were late the year before too. A late filing penalty uk companies receive for accounts arrives automatically, and nobody rings first.

The 5 items it can change, and the many it cannot

Only a short list of changes can travel on the statement to the SIC code, the statement of capital, the trading status of shares, an exemption from reporting people with significant control, and shareholder information.

That is 5 items in total, and no more. Everything else has its own filing.

A new director, a change of registered office, a change of name, a change to the people with significant control: none of those ride along with the annual statement, and I have watched people lose the better part of a quarter waiting for a change to appear on the register because they had assumed the yearly form would sweep it up.

You also have to provide a registered email address if you have not already given one. Companies House uses it to contact the company and expects somebody to read what arrives. It is not published on the public register, which is the opposite of what most people guess.

I had assumed for a long time that a change of registered office could ride along with the statement. It cannot, and the company I tried it on spent 7 weeks showing an address it had left.

The step that now sits in front of filing

Before filing, you may need to verify your identity through GOV.UK One Login and hold a personal code that proves it.

If the company has more than 1 director, you must hold every director's personal code before the filing will go through. Not just your own code, but every single one of them.

I find that requirement harder to plan around than the deadline itself, because the 14 days are predictable and a co-director in another time zone who has not started verification is not. An email address can only be used once to verify an identity, so a shared company mailbox will carry exactly 1 person through it.

A route exists for people the app cannot handle. An Authorised Corporate Service Provider, meaning an accountant, a solicitor or another professional supervised for anti money laundering purposes, can verify somebody on their behalf.

A founder I act for started verification 3 days before the window closed, on the assumption that the code arrives by return. She got it in time. I would not build a plan on that.

What I check now, in March and in every other month

I look the company up on the register before I do anything else, because the confirmation statement date shown there is the only version that counts and my own notes have been wrong at least twice.

Next comes the question of whether every director holds a personal code. Not whether they have heard of verification. Whether they hold the code, because those are different states and only 1 of them lets a filing through.

After that I ask what has actually changed in the year, and I sort each change into the 5 things the statement can carry and the everything else that needs its own form. That sorting takes about 10 minutes and it is the difference between a filing that lands and a quarter spent wondering why the register still shows an old director.

None of those 3 checks is clever. It is 3 checks that take under half an hour, and I only built the habit after the March filing taught me that reading a page is not the same as having understood it.

An aside about what the register is for

This is not a form about your year. It is a form about what strangers can see.

Registered office, directors, people with significant control, SIC code and share capital all sit on a public record, and the superseded version stays next to the current one, so the history is readable by anybody who types in the company number.

I keep thinking about that when somebody treats the statement as an administrative chore. It is the annual moment when the company's public description is either confirmed as accurate or quietly left wrong for another year. Anyway, back to the dates themselves.

A register that nobody keeps current is just an archive of intentions, and the annual statement is the only moment anybody is asked to look.

What I do not know

I do not know how many companies are struck off each year specifically for failing to file a confirmation statement, because the strike off figures I can find do not separate the reason.

I went looking for that split twice and came away with nothing I would quote. My suspicion is that the number is larger than people expect and smaller than the fear suggests, and I would not defend that as anything but a suspicion.

What is published, and what this piece is built on, is the shape of the rule: 12 months, then 14 days, moved forward by any early filing, 50 pounds online, up to 5,000 pounds and a possible strike off for not doing it at all. Strike off for late filing is not a scare story invented by accountants. It is written on the same page as the fee.

Why the shortest window is on the least important form

Of every filing a company makes, this is the cheapest a company makes and it carries the tightest deadline of any of them. Accounts get 9 months after the year end and 21 months for a first set. Corporation Tax gets 9 months and a day. The statement that says nothing has changed gets 14 days.

I have no explanation for that I would defend. My instinct is that it follows from the review period being a rolling 12 months rather than a fixed year end, so the window has to be short to keep the register current, but that is reasoning backwards from the rule rather than anything published.

What I can say is that the asymmetry catches people who are otherwise organised. They plan around the big numbers, the 21 months and the 1,500 pound ceiling, and get caught by the small one that costs 50 pounds and can end the company.

Whatever the reason, the asymmetry is not going to change because it inconveniences people who file for a living.