ECCTA – Implications for the travel industry & ABTA members The Economic Crime and Corporate Transparency Act (ECCTA) is a significant UK legislative reform aimed at tackling fraud, financial crime and improving corporate transparency. The main parts of it came into effect on 1 September 2025. (high level ECCTA overview - link below) Impacts on the travel industry and ABTA members:What Is ECCTA?• ECCTA introduces sweeping changes to company law and corporate governance.• It strengthens the powers of Companies House, introduces new offences like failure to prevent fraud, and imposes stricter requirements on company directors and those filing corporate information. • It applies to all sectors, employees, agents, and associated persons acting on the organisation’s behalf.• Offence can be committed overseas provided there is a UK nexus.• A strict liability offence, unless adequate procedures can be evidenced.Are all Organisations liable?No. The offence only applies to large, incorporated bodies and partnerships across all sectors and industries that meet two out of the three following criteria:• 250+ staff• £36 million annual turnover• £18 million held assets.Link to high level ECCTA overview below. Economic Crime and Corporate Transparency Act 2023:The Economic Crime and Corporate Transparency Act (ECCTA) is a significant UK legislative reform aimed at tackling fraud, financial crime and improving corporate transparency. The main parts of it came into effect on 1 September 2025. (high level ECCTA overview - link below) Impacts on the travel industry and ABTA members:What Is ECCTA?• ECCTA introduces sweeping changes to company law and corporate governance.• It strengthens the powers of Companies House, introduces new offences like failure to prevent fraud, and imposes stricter requirements on company directors and those filing corporate information. • It applies to all sectors, employees, agents, and associated persons acting on the organisation’s behalf.• Offence can be committed overseas provided there is a UK nexus.• A strict liability offence, unless adequate procedures can be evidenced.Are all Organisations liable?No. The offence only applies to large, incorporated bodies and partnerships across all sectors and industries that meet two out of the three following criteria:• 250+ staff• £36 million annual turnover• £18 million held assets.Link to high level ECCTA overview below. Impact on the travel industryThe travel sector, like all UK-based businesses, must adapt to ECCTA’s new compliance landscape:• Increased corporate scrutiny: travel companies must ensure accurate filings and transparency in ownership and control structures.• Fraud prevention obligations: larger travel firms are now liable if associated persons commit fraud to benefit the company, unless they can prove reasonable prevention measures were in place (see attached link).• Operational adjustments: companies must maintain a valid registered office and email address and affirm lawful business purposes annually.• Reputational risk: non-compliance could lead to fines and reputational damage, especially in a consumer-facing industry like travel.Enforcement and sanctions• Law enforcement agencies gain improved access to company data.• Expanded powers to seize and recover crypto assets linked to crime.• Powers to impose significant financial penalties.ComplianceCompliance with ECCTA is not negotiable - as an organisation you will need to ensure you have developed and implemented the necessary anti-fraud procedures within your organisation. This came into effect on 1st September 2025, with no grace period while the provisions are introduced.An organisation’s fraud prevention framework should be informed by the following six principles:• Top level commitment• Risk assessment• Proportionate prevention procedures• Due diligence• Communication and training• Monitoring and reviewWhilst not exhaustive, the check list below signposts areas where ABTA members can demonstrate compliance in line with the six guiding principles. WeightmansECCTA compliance checklist for travel companiesECCTA compliance checklist for travel companiesAreaAction requiredWhy it mattersIdentity verification Verify identities of directors and PSCs via Companies HouseMandatory for all UK companies from 18 November 2025 Lawful purpose statementUpdate incorporation and confirmation statements to include lawful purpose Required under ECCTA reformsRegistered Office and emailEnsure physical address (no PO boxes) and provide a registered emailFor official communications and legal noticesFraud risk assessmentConduct a fraud risk review across operations (e.g. bookings, refunds, supplier payments)To identify vulnerabilities and design controls Prevention proceduresImplement reasonable procedures to prevent fraud (e.g. staff training, whistleblowing channels)To avoid liability under the “failure to prevent fraud” offenceStaff training Educate employees on fraud risks, reporting lines, and ethical conductFrontline staff are often the first line of defence Supplier due diligenceVet third-party agents, tour operators, and payment processorsTo avoid exposure from external fraud Data accuracy Review filings with Companies House for accuracy and completenessCompanies House now has powers to challenge false data Board oversightEnsure directors are aware of ECCTA obligations and monitor complianceGovernance is key to accountability Find out more about Weightmans here.
