Address Manipulation in Company Records: Legal Risks and Compliance Implications
How Deliberate Address Variations Breach UK Corporate Law and Undermine KYC/Audit Processes
This example demonstrates how minor address formatting inconsistencies in Companies House records can lead to incomplete search results, highlighting systemic data quality issues with significant implications for audit and KYC processes.
Disclaimer:
The companies and addresses referenced in this example are used solely to illustrate how address variations can affect search results and compliance processes. No allegation of wrongdoing or non-compliance is made against any of the entities mentioned.
A search was made in Companies House on an address written as “91 Plantation Road, Oxford, United Kingdom, OX2 6JE”:
One company was returned in the search:
“1 Result
THREE IDLE WOMEN LLP(link opens a new window)
Active
Limited liability partnership
OC455534 - Incorporated on 17 February 2025
91 Plantation Road, Oxford, United Kingdom OX2 6JE”
A search made with the address simplified to “91 Plantation Road, Oxford” returns 4 companies.
“4 results
CEBMI LIMITED(link opens a new window)
Dissolved
Private limited company
07355644 - Incorporated on 24 August 2010
Dissolved on 19 January 2016
91 Plantation Road, Oxford, Oxfordshire OX2 6JE
SIC codes - 72190
THE MUSIC EMPORIUM LTD(link opens a new window)
Active
Private limited company
14927349 - Incorporated on 9 June 2023
91 Plantation Road, Oxford, England OX2 6JE
SIC codes - 59200, 85520, 90010
CACHE LIMITED(link opens a new window)
Active
Private limited company
06767142 - Incorporated on 5 December 2008
91 Plantation Road, Oxford, Oxon OX2 6JE
SIC codes - 58290, 62012, 72190, 72200
THREE IDLE WOMEN LLP(link opens a new window)
Active
Limited liability partnership
OC455534 - Incorporated on 17 February 2025
91 Plantation Road, Oxford, United Kingdom OX2 6JE”
Perplexity AI’s Address Variation Analysis
The search discrepancies arise from inconsistent address formatting in Companies House records:
Jurisdictional variations: "Oxfordshire" vs "Oxon" vs "England" vs "United Kingdom"
Component ordering: Postcode placement and comma usage differences
Abbreviation inconsistencies: Full county names vs historical abbreviations (Oxon)
These variations create non-exact string matches in database queries. While humans recognize these as equivalent addresses, automated systems often treat them as distinct entries without advanced normalization.
Implications for Audit Software
Risk of incomplete due diligence
Auditors relying on exact-match searches might miss:Data aggregation challenges
Address inconsistencies complicate:Increased manual verification needs
Requires human intervention to reconcile:
KYC Software Challenges
False negative risks
Basic string-matching systems might:Compliance gaps
ECCTA 2023 requirements for "appropriate addresses" (implemented March 2024) remain challenging due to:Resource intensiveness
KYC systems must now handle:
Recommended Mitigations
Solution, Implementation, Benefit
Fuzzy matching algorithms, Weighted text similarity scores for address components, Reduces false negatives 56
API standardization, Integration with Royal Mail's Postcode Address File (PAF), Ensures address validity 37
Contextual analysis, Cross-referencing with land registry and utility records, Verifies operational presence 24
Regular data cleansing, Automated updates from Companies House bulk data, Maintains current records 13
The ECCTA's upcoming identity verification requirements (from April 2025) may eventually reduce these issues, but current systems must account for historical inconsistencies through enhanced parsing logic and multi-source verification23.
Deliberate variation of company address
Deliberately varying company addresses to create non-match errors in official records engages multiple legal provisions, with primary breaches occurring under:
Companies Act 2006
Section 1112
Criminalises "knowingly or recklessly" submitting false/misleading information to Companies House 135
Applies to address variations intended to:
Evade detection in audit/KYC checks
Obscure corporate relationships
Facilitate fraudulent activity
Penalty: Unlimited fines and/or 2 years imprisonment 3
Fraud Act 2006
Section 2 (Fraud by false representation)
Covers deliberate address manipulation to:
Requires proof of dishonest intent and foreseeable risk of loss
Maximum penalty: 10 years imprisonment 6
Economic Crime and Corporate Transparency Act 2023
Section 28
Requires "appropriate addresses" verifiable through geolocation checks
Prohibits PO Box addresses from March 2024 5
Section 105Empowers Companies House to challenge suspicious addresses
Mandates 28-day compliance periods for corrections 5
Key Enforcement Mechanisms
Companies House may:
Initiate criminal prosecutions under s.1112 CA 2006
Use default addresses (PO Box 438, Cardiff) for non-compliant entities 7
CPS guidance treats systematic address manipulation as fraud where:
Multiple variations exist across linked entities
Pattern indicates intentional deception 6
This legal framework creates overlapping liabilities – a single address variation could simultaneously breach Companies Act filing requirements and constitute fraud if part of broader deceptive practices. Recent ECCTA reforms (effective 2025) will introduce additional identity verification requirements to reduce such risks 5.