The Economic Crime and Corporate Transparency Act 2023: Impact on CPD Accreditation
The Economic Crime and Corporate Transparency Act 2023: Impact on CPD Accreditation
Introduction
The Economic Crime and Corporate Transparency Act 2023 represents the most significant reform to UK corporate transparency in decades. Designed to combat economic crime, money laundering, and corporate opacity, the Act fundamentally changes expectations around business transparency, accountability, and identity verification.
For the CPD sector—particularly CPD accreditation organisations—these reforms have profound implications. The CPD accreditation landscape has historically operated with variable transparency. Some organisations operate as registered companies with clear ownership and governance, whilst others function as brands, sole traders, or informal arrangements with minimal public accountability.
The Economic Crime Act doesn't directly regulate CPD provision or accreditation. However, it establishes new baseline expectations for corporate transparency that have broader implications for trust, accountability, and consumer protection across all sectors. When professionals and training providers choose CPD accreditation, they're making trust-based decisions. Transparency about who operates an accreditation organisation, how it's governed, and its accountability structures matters fundamentally to that trust.
This guide explains the Economic Crime and Corporate Transparency Act 2023, its key provisions affecting business transparency, and its implications for the CPD accreditation sector. We also outline The CPD Register's position on applying transparency principles across all CPD accreditation organisations—limited companies and non-limited structures alike.
Important Context: This guide provides educational information about legislation and The CPD Register's policies. It is not legal advice. The Economic Crime Act is complex legislation with many provisions beyond transparency. Organisations should seek legal advice about their specific compliance obligations.
About This Guide and The CPD Register's Position
Our Role and Perspective
The CPD Register's Mission:
The CPD Register certifies CPD accreditation organisations that meet published quality standards. Central to our mission is ensuring transparency and accountability in the CPD sector. We believe professionals choosing CPD accreditation deserve to know who operates accreditation organisations and how they're governed.
Our Position on the Economic Crime Act:
Whilst the Economic Crime and Corporate Transparency Act primarily affects registered companies, The CPD Register applies its transparency principles to all CPD accreditation organisations we certify—regardless of legal structure.
Why We Take This Position:
Consumer Protection Focus:
- Professionals need to know who they're trusting with quality assurance
- Transparency enables informed decisions
- Accountability requires identifiable operators
- Trust depends on knowing who stands behind claims
Sector Credibility:
- Variable transparency undermines sector trust
- Professionals deserve consistent standards
- Quality assurance requires accountability
- Sector maturity demands transparency
Consistent Standards:
- Legal structure shouldn't determine transparency expectations
- Limited companies, sole traders, and informal brands all make quality assurance claims
- Consumers can't distinguish legal structures easily
- Standards should reflect function, not just form
Our Certification Requirements:
CPD accreditation organisations seeking CPD Register certification must demonstrate:
- Clear identification of who operates the organisation
- Transparency about governance and decision-making
- Verifiable accountability structures
- Whether registered company, sole trader, partnership, or other structure
What This Means:
We don't require all accreditation organisations to be limited companies. However, we do require transparency equivalent to Companies House standards regardless of structure:
- Who operates the organisation?
- Who makes decisions?
- How is the organisation governed?
- What accountability mechanisms exist?
- Where is it based and how can it be contacted?
Why This Guide:
This guide explains the Economic Crime Act's transparency provisions and why we believe these principles should apply across the CPD accreditation sector, regardless of legal structure.
Understanding the Economic Crime and Corporate Transparency Act 2023
What is the Act?
The Economic Crime and Corporate Transparency Act 2023 is UK legislation aimed at combating economic crime, fraud, and money laundering. It received Royal Assent in October 2023 and provisions came into force throughout 2024.
Primary Objectives:
- Combat economic crime and money laundering
- Increase corporate transparency
- Reform Companies House
- Improve business accountability
- Enable better investigation and enforcement
Key Provisions
1. Companies House Reform
Identity Verification:
- New directors must verify their identity
- Verification via government-approved methods
- Prevents anonymous or fraudulent directorships
- Increased accountability for company officers
Enhanced Information Requirements:
- More comprehensive company information
- Ongoing verification of registered details
- Powers for Companies House to query suspicious filings
- Regular confirmation of accuracy
Accuracy and Powers:
- Companies House can reject or remove inaccurate information
- Annotation of disputed information
- Greater investigation powers
- Criminal sanctions for false information
2. Beneficial Ownership Transparency
People with Significant Control (PSC):
- Enhanced PSC register requirements
- Verification of beneficial ownership
- Restrictions on accessing PSC information (to prevent misuse)
- Clearer identification of who ultimately controls companies
3. Corporate Criminal Liability Reform
Failure to Prevent Fraud:
- New corporate criminal offence
- Companies can be liable for fraud by employees/agents
- Must have reasonable procedures to prevent fraud
- Significant penalties for failures
4. Anti-Money Laundering Powers
Enhanced Powers:
- Stronger investigation tools
- Information sharing between agencies
- Seizing and freezing suspicious funds
- International cooperation
Timeline
2023: Act receives Royal Assent (October) 2024: Phased implementation throughout year Ongoing: Continued roll-out of provisions
Transparency Expectations: Why They Matter for CPD Accreditation
The Trust Equation in CPD Accreditation
CPD accreditation is fundamentally a trust relationship:
Training Providers Trust Accreditors:
- Their accreditation means something
- Assessment is genuine and rigorous
- Claims are accurate and substantiated
- Organisation is accountable for standards
Professionals Trust Accreditors:
- Accredited courses meet quality standards
- Accreditation represents independent assessment
- Claims about standards are accurate
- Someone accountable stands behind the accreditation
This Trust Requires Transparency:
- Who operates the accreditation organisation?
- How is it governed?
- Who makes decisions about standards?
- What accountability exists if problems arise?
- Is it truly independent?
The Current Transparency Gap
Variable Standards Currently Exist:
Some CPD Accreditation Organisations:
- Operate as registered companies with clear ownership
- Publish directors and governance information
- Provide transparent accountability
- Verifiable through Companies House
Others Operate With Minimal Transparency:
- Brands without clear company registration
- Unknown or unclear operators
- Sole traders or informal arrangements not disclosed
- Difficult or impossible to verify who operates them
- Limited accountability mechanisms
The Problem:
Professionals and training providers often cannot distinguish between:
- Transparent, accountable accreditation organisations
- Opaque brands with unknown operators
- Self-accreditation disguised as independent bodies
- Potentially fraudulent or misleading operations
Without transparency, informed choice is impossible.
Why Legal Structure Matters (And Doesn't)
Limited Companies Provide Built-In Transparency:
- Companies House registration (public)
- Directors identified (public record)
- Registered address (public)
- Annual accounts (usually public)
- Verifiable and accountable
Non-Limited Structures Can Also Be Transparent:
- Sole traders can clearly identify themselves
- Partnerships can disclose partners
- Unincorporated associations can publish governance
- Transparency is about disclosure, not structure
The Issue:
Some CPD accreditation organisations use legal structures that don't require public registration to avoid transparency. They:
- Operate as brands without clear operators
- Present as organisations without disclosing sole trader status
- Create impression of formal entities without substance
- Avoid accountability through opacity
Consumer Protection Gap:
Professionals choosing accreditation cannot easily verify:
- Who operates the accreditation organisation
- Whether it's genuinely independent
- Who is accountable for standards
- Whether claims are substantiated
The CPD Register's Transparency Requirements
Our Certification Standards
CPD accreditation organisations seeking certification must meet transparency requirements regardless of legal structure.
Requirement 1: Clear Operator Identification
What We Require:
- Clear statement of who operates the organisation
- If limited company: company name and registration number
- If sole trader: individual's name clearly disclosed
- If partnership: partners identified
- If unincorporated association: governance disclosed
Why This Matters: Professionals need to know who stands behind accreditation claims.
Requirement 2: Governance Transparency
What We Require:
- How decisions about standards are made
- Who makes those decisions
- Any advisory boards or governance structures
- Independence mechanisms (if claimed)
Why This Matters: Quality assurance requires robust governance. Consumers should understand decision-making structures.
Requirement 3: Contact and Accountability
What We Require:
- Physical address (not just PO box)
- Contact details (phone, email)
- Verification of address and contact information
- Accountability mechanisms
Why This Matters: If issues arise, training providers and professionals need recourse.
Requirement 4: Independence Verification
What We Require:
- If claiming independence, evidence of separation
- Disclosure of any conflicts of interest
- Transparency about related entities
- Clear distinction between accreditor and training provision
Why This Matters: Self-accreditation presented as independent is fundamentally misleading. True independence must be verifiable.
Requirement 5: Ongoing Transparency Maintenance
What We Require:
- Annual confirmation of information accuracy
- Notification of material changes
- Maintenance of public transparency
- Continued accountability
Why This Matters: Transparency isn't a one-time exercise. It requires ongoing commitment.
Equivalent Transparency Regardless of Structure
Our Approach:
We don't mandate legal structure. CPD accreditation organisations can be:
- Limited companies ✓
- Sole traders ✓
- Partnerships ✓
- Unincorporated associations ✓
- Other structures ✓
However, transparency requirements are equivalent across all structures:
If Limited Company:
- Companies House registration verified
- Directors identified
- Governance published
- Contact details verified
If Sole Trader:
- Individual operating it clearly identified
- Trading name disclosed as sole trader
- Contact details provided
- Accountability mechanisms clear
If Other Structure:
- Structure explained clearly
- Operators/decision-makers identified
- Governance disclosed
- Accountability demonstrated
The Standard:
Transparency equivalent to what Companies House provides for limited companies:
- Who operates it? (Clear answer)
- Who decides standards? (Clear answer)
- How is it governed? (Clear answer)
- How is it accountable? (Clear answer)
- Where is it and how contacted? (Clear answer)
Why This Matters: Case Studies
Scenario 1: The Transparent Limited Company
Example: "Professional CPD Accreditation Ltd" is a limited company accrediting courses in the legal sector.
Transparency:
- Companies House registration: 12345678
- Directors: Jane Smith, John Brown (publicly listed)
- Registered address: 123 High Street, London
- Accounts filed annually
- Website clearly displays company information
- Governance structure published
Consumer Can Verify:
- Who operates the company
- Directors' identities
- Financial viability (through accounts)
- Contact information
- Accountability (directors liable)
Assessment: HIGH TRANSPARENCY ✓
Scenario 2: The Identified Sole Trader
Example: "Sarah Johnson CPD Accreditation" is a sole trader accrediting courses in the care sector.
Transparency:
- Website clearly states: "Sarah Johnson CPD Accreditation is a sole trader business operated by Sarah Johnson"
- Sarah's qualifications and background disclosed
- Contact details provided (business address, phone, email)
- Process and criteria published
- Personal accountability clear
Consumer Can Verify:
- Who operates the accreditation (Sarah Johnson)
- Background and qualifications
- How to contact
- Accountability (Sarah personally accountable)
Assessment: HIGH TRANSPARENCY ✓
Scenario 3: The Opaque Brand
Example: "UK CPD Excellence" presents as an accreditation organisation.
Lack of Transparency:
- No company registration found
- No individual identified as operator
- Generic contact form only
- No physical address disclosed
- "About Us" vague about who operates it
- Governance unclear
Consumer Cannot Verify:
- Who operates this organisation
- Whether it's a company, sole trader, or brand
- Who makes decisions
- How to hold it accountable
- Whether it's genuinely independent
Assessment: LOW TRANSPARENCY ✗
Questions Arise:
- Is this self-accreditation under a different brand?
- Who stands behind these accreditation claims?
- How can training providers contact with concerns?
- Is this legitimate or potentially fraudulent?
Scenario 4: The Hidden Self-Accreditation
Example: "Independent CPD Standards Board" accredits courses from "ABC Training Ltd"
Investigation Reveals:
- Same director operates both organisations
- Shared address
- ABC Training Ltd accredits its own courses
- No disclosure of relationship
- "Independent" claim misleading
Transparency Issue:
- Self-accreditation not disclosed
- Independence claimed falsely
- Consumers misled about relationship
- Fundamental conflict of interest hidden
Assessment: FUNDAMENTALLY MISLEADING ✗✗
Implementation: What CPD Accreditation Organisations Should Do
For Limited Companies
Basic Compliance:
- Ensure Companies House information current
- Complete identity verification for directors
- File accounts and confirmations on time
- Maintain accurate registered information
Enhanced Transparency (CPD Register Standard):
- Display company registration prominently on website
- Link to Companies House page
- Publish governance information
- Maintain clear contact details
- Disclose any related entities
For Sole Traders
Transparency Requirements:
- Clearly identify yourself as the operator
- State trading name is sole trader business
- Provide contact details
- Disclose your background/qualifications
- Explain governance (your process)
Example Disclosure:
"[Trading Name] is a sole trader business operated by [Your Name]. I personally assess all courses against published criteria and am accountable for accreditation decisions."
For Partnerships
Transparency Requirements:
- Identify partners
- Explain partnership structure
- Disclose governance
- Provide contact for each partner
- Clarify decision-making process
For Other Structures
Transparency Requirements:
- Explain the structure clearly
- Identify who operates it
- Disclose governance
- Demonstrate accountability
- Provide verification
Key Principle:
Regardless of structure, answer these questions transparently:
- Who operates this accreditation organisation?
- Who makes decisions about standards?
- How is the organisation governed?
- How is it accountable?
- How can it be contacted?
Benefits of Transparency
For CPD Accreditation Organisations
Credibility:
- Transparency builds trust
- Demonstrates professionalism
- Differentiates from opaque competitors
- Shows commitment to accountability
Competitive Advantage:
- Training providers choose transparent accreditors
- Professionals trust verifiable organisations
- Quality signal to the market
- Reduced risk perception
Risk Mitigation:
- Clear accountability protects against challenges
- Transparency reduces regulatory risk
- Easier to defend against complaints
- Professional reputation enhanced
Relationship Building:
- Trust with training providers
- Confidence from professionals
- Partnership opportunities
- Sector credibility
For Training Providers
Informed Decisions:
- Know who you're working with
- Verify independence and credibility
- Assess governance and quality
- Evaluate accountability
Risk Management:
- Due diligence simplified
- Verify legitimacy easily
- Identify conflicts of interest
- Protect your reputation
Marketing Clarity:
- Explain accreditation to clients clearly
- Credible quality assurance
- Transparent credentials
- Professional positioning
For Professionals
Confidence:
- Trust in accredited courses
- Informed CPD choices
- Verification of quality claims
- Accountability if issues arise
Consumer Protection:
- Ability to research accreditors
- Identify misleading claims
- Avoid questionable accreditation
- Make evidence-based decisions
Common Questions
Does the Economic Crime Act require all CPD organisations to be limited companies?
No. The Economic Crime and Corporate Transparency Act regulates limited companies, LLPs, and other registered entities. It doesn't mandate legal structure for CPD organisations.
However, The CPD Register believes transparency principles from the Act should apply across all CPD accreditation organisations, regardless of structure.
Do I need to register a company to offer CPD accreditation?
Legally: No specific requirement to be a company to accredit CPD.
Our Standard: No requirement to be a company, but equivalent transparency required regardless of structure.
Consideration: Limited company structure provides built-in transparency and accountability. Other structures require deliberate transparency measures.
What if I'm a sole trader offering CPD accreditation?
You can operate as a sole trader. Our transparency requirements mean:
- Clearly disclose you're a sole trader
- Identify yourself as the operator
- Provide contact details
- Explain your process and governance
- Be transparent about your accountability
This is acceptable and transparent.
Why does The CPD Register apply these standards to all structures?
Consumer Protection: Professionals can't easily distinguish legal structures. Transparency shouldn't depend on structure expertise.
Consistent Standards: Function matters more than form. All CPD accreditation organisations make quality assurance claims—all should be transparent.
Sector Maturity: Professional sectors deserve consistent transparency standards regardless of legal technicalities.
Trust Foundation: Transparency builds trust essential to CPD sector credibility.
What about established accreditation organisations?
Existing organisations have time to implement transparency measures. The CPD Register works with organisations to enhance transparency progressively.
Grandfathering: We recognise established organisations may need time to adjust. However, transparency requirements must be met for certification or recertification.
The CPD Register Certification and Transparency
Our Verification Process
When organisations seek CPD Register certification, we verify:
Identity and Operator:
- Limited company: Companies House verification
- Sole trader: Individual identification and verification
- Partnership: Partner identification
- Other: Appropriate structure verification
Governance:
- Decision-making processes
- Standards development approach
- Independence mechanisms (if claimed)
- Accountability structures
Contact and Address:
- Physical address verified
- Contact details tested
- Correspondence sent to address
- Verification of legitimacy
Transparency:
- Public disclosure of operator
- Website clarity about structure
- Accessible information
- Consumer-facing transparency
Ongoing Monitoring
Annual Verification:
- Confirmation of information accuracy
- Notification of material changes
- Continued transparency maintenance
- Address and contact verification
Audit:
- Sample audits of transparency
- Website monitoring
- Public information verification
- Complaint investigation
Action:
- Non-compliance addressed
- Transparency breaches investigated
- Certification suspended for failures
- Removal for persistent non-transparency
Key Takeaways
The Economic Crime Act 2023:
- Significantly reforms UK corporate transparency
- Primarily affects registered companies
- Establishes new baseline expectations
- Emphasises accountability and verification
CPD Sector Implications:
- Transparency matters for trust-based relationships
- CPD accreditation depends on credibility
- Variable transparency undermines sector
- Consumers deserve consistent standards
The CPD Register's Position:
- Transparency principles apply to all structures
- Legal form shouldn't determine accountability
- Equivalent transparency regardless of structure
- Consumer protection focus
Requirements for All Structures:
- Clear identification of operator
- Governance transparency
- Contact and accountability
- Independence verification (if claimed)
- Ongoing transparency maintenance
Benefits:
- Credibility and trust
- Competitive advantage
- Risk mitigation
- Sector maturity
- Consumer protection
Implementation:
- Limited companies: ensure compliance + enhanced transparency
- Sole traders: clearly identify and disclose
- All structures: answer transparency questions
- Ongoing: maintain and update information
Resources
Economic Crime Act Information:
The CPD Register:
Related Guidance:
Questions about transparency and certification?
Contact The CPD Register:
- Email: [email protected]
- Phone: 0333 1889 783
About The Author:
The CPD Register Ltd, a UK independent certification body for CPD accreditation organisations. The CPD Register works to improve transparency and quality standards across the CPD sector, including advocating for consistent transparency expectations regardless of legal structure.
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