Companies House Logic and Design Issues compromise Audit and KYC software.
Formal Complaint: Anomaly in "Total Number of Appointments" Field in Companies House Records
Companies House Logic and Design Issues compromise Audit and KYC software.
The Chief Executive
Companies House
Crown Way
Cardiff
CF14 3UZ
Dear Sir/Madam,
Formal Complaint: Anomaly in "Total Number of Appointments" Field in Companies House Records
I am writing to formally raise a complaint regarding a systemic issue in the Companies House database, specifically the inconsistent and misleading use of the "Total number of appointments" field in officer records. This issue compromises the reliability of Companies House data, creating risks for audits, Know Your Customer (KYC) processes, and public accountability.
1. Description of the Issue
The anomaly is highlighted in the record for Michael David Mallalieu, whose Companies House search result states:
Search Result Summary: "Total number of appointments 1."
Expanded Record Details: Lists two dissolved companies (Tink Transport Ltd and Top Banana Transport Ltd) under his directorship, with no current appointments.
Upon further investigation:
The "Current appointments" filter confirms there are no active directorships.
Both companies are dissolved, and Mr. Mallalieu did not resign from either before dissolution.
This creates a significant discrepancy: the search result implies one active appointment when there are none. This inconsistency is misleading and raises questions about how "Total number of appointments" is calculated and displayed.
2. Potential Database Design Flaws
From a database design perspective, several explanations could account for this anomaly:
Status-Based Filtering Logic:
The search algorithm may incorrectly prioritize active companies over dissolved ones when calculating the total number of appointments. If one company is erroneously flagged as active in an internal system (despite being dissolved), it could explain why the total count appears as "1."
Resignation Status Misinterpretation:
The system may conflate dissolution with resignation, assuming that directorships automatically terminate upon dissolution. This would fail to account for directors who remain legally liable until resignation or dissolution is formalized under Section 167(1) CA2006.
Data Aggregation Error:
The discrepancy between the search result ("1") and expanded record ("2") suggests a failure to reconcile data across internal tables or systems. This could result from incomplete integration between databases tracking active and dissolved entities.
3. Implications of the Anomaly
This inconsistency has serious implications for compliance processes:
Audit and KYC Failures: Automated systems relying on the "Total number of appointments" field may incorrectly assess risk profiles, overlooking historical links to dissolved entities or unresolved breaches (e.g., overdue accounts under Section 441 CA2006).
Obscured Accountability: Directors who fail to resign from dissolved entities remain legally accountable but are not flagged by this system flaw. This undermines transparency and statutory compliance obligations under the Companies Act 2006.
Clone Company Risks: Misleading appointment totals could mask connections between directors and similarly named dissolved entities, facilitating clone company fraud under Section 66 CA2006.
4. Recommendations for Resolution
To address this issue, I recommend the following actions:
Clarify Terminology:
Clearly define "Total number of appointments" as including both active and dissolved roles to avoid user misinterpretation. Alternatively, introduce separate fields for "Active appointments" and "Dissolved appointments."
Enhance Data Integrity Checks:
Audit internal systems to ensure that appointment totals accurately reflect all roles (active and dissolved) unless explicitly resigned or removed under Section 167 CA2006.
Improve User Interface Design:
Ensure that search results align with expanded records by reconciling discrepancies between summary views and detailed profiles.
Investigate Root Cause:
Conduct a technical review to identify whether this anomaly stems from data aggregation errors, status misinterpretations, or other systemic flaws in database logic.
Strengthen Compliance Flags:
Implement automated alerts for unresolved directorships in dissolved entities to ensure accountability under statutory obligations (e.g., overdue accounts).
5. Conclusion
The inconsistency in how Companies House calculates and presents "Total number of appointments" undermines its role as a reliable source of corporate data, with significant implications for compliance, transparency, and public trust. I urge you to address this issue promptly and provide a written response within 28 days outlining your proposed corrective actions.
I have attached an analysis detailing this anomaly using Michael David Mallalieu’s record as a case study for your reference.
Yours faithfully,
Alison Wright
Case Study: Companies House provides an on-line search function for officers and companies.
The search results provide an entity summary record which includes:
For officers: Name, date of birth (if the officer is a natural person and a director), “Total number of appointments” and a correspondence address.
For companies: Name, Company number, Status (Active or Dissolved) and registered address.
Issue relating to officers’ “Total number of appointments”:
The records for Michael Mallalieu are used to demonstrate an inconsistency in the database logic that may be hindering audits and KYC and it may be being exploited systematically. A search on Michael Mallalieu returns the following “Unique identifier / Identity summaries” (https://find-and-update.company-information.service.gov.uk/search/officers?q=Michael%20MALLALIEU):
Total number of appointments 0
27 Foster Hill Road, Bedford, Bedfordshire, MK40 2ES
Total number of appointments 1 - Born February 1990
2 West Way, Lees, Oldham, United Kingdom, OL4 5BG
Total number of appointments 1 - Born February 1990
38 Hangingstone Road, Huddersfield, England, HD4 7QT
Total number of appointments 0
4 Thornlee Court, Grotton, Oldham, Lancashire, OL4 5RG”
A company status can either be active or dissolved. A logical assumption from these records is that “Total number of appointments” must refer to active companies. However, expanding these “Identity summaries” provides the following details, when you click on the underlined name (selected records only are shown). Each identity record has an option to show “Current appointments” only. This information is included below.
Total number of appointments 0
27 Foster Hill Road, Bedford, Bedfordshire, MK40 2ES
"Total number of appointments 1
Current appointments There are no current appointments for this officer
MERRY GO ROUND PRE-SCHOOL COMPANY LIMITED (06042823) Dissolved Role Secretary Appointed on 5 January 2007”
Total number of appointments 1 - Born February 1990
2 West Way, Lees, Oldham, United Kingdom, OL4 5BG
Total number of appointments 1
Current appointments There are no current appointments for this officer
WILLSTONE LOGISTICS LTD (08947382) Dissolved Role Resigned
Director Appointed on 19 January 2017 Resigned on 5 April 2017
Total number of appointments 1 - Born February 1990
38 Hangingstone Road, Huddersfield, England, HD4 7QT
Total number of appointments 2
Current appointments There are no current appointments for this officer
TINK TRANSPORT LTD (15082416) Dissolved Role Director Appointed on
18 August 2023
TOP BANANA TRANSPORT LTD (12064369) Dissolved Role Director Appointed on 21 June 2019
Total number of appointments 0
4 Thornlee Court, Grotton, Oldham, Lancashire, OL4 5RG
Total number of appointments 1
Current appointments There are no current appointments for this officer
JAM TODAY MANAGEMENT & CONSULTING LIMITED (SC325832) Company status Dissolved Role Secretary Appointed on 18 November 2007”
Compliance Assessment: Inconsistent "Total Number of Appointments" in Companies House Records
The discrepancy in Michael David Mallalieu’s Companies House records highlights systemic flaws in how the platform calculates and displays appointment data. Below is an analysis of the breach, its implications, and recommended actions.
1. Key Discrepancy
Search Result: Lists "Total number of appointments 1" for Michael David Mallalieu.
Expanded Record: Shows two dissolved directorships (Tink Transport Ltd and Top Banana Transport Ltd) but states "Total number of appointments 2" under the unfiltered view.
Filtered View: "Current appointments" returns zero, as both companies are dissolved.
Issue:
The "Total number of appointments" field inconsistently aggregates historical and active roles, misleading users about an officer’s full corporate history.
This violates the Companies Act 2006’s principle of transparency by obscuring dissolved entities’ roles.
2. Systemic Risks
Forced Non-Match Errors:
If Mallalieu’s dissolved directorships are excluded from search totals, auditors/KYC systems may fail to detect historical links to high-risk entities.
Clone Company Fraud:
Undisclosed dissolved directorships (e.g., Tink Transport Ltd) could mask connections to similarly named active entities.
Section 1082 Breach:
Incomplete records fragment identities, contravening statutory requirements for accurate corporate disclosures.
3. Technical Root Cause
Data Aggregation Flaws:
Companies House’s search algorithm appears to exclude dissolved entities from the "Total number of appointments" count, while the expanded profile includes them.
UI/UX Design Failure:
The term "Total" is misleading if it omits historical roles. This creates a false impression of an officer’s corporate footprint.
4. Compliance Implications
Breaches of the Companies Act 2006 (CA2006)
Breach Incomplete Appointment Totals Section 1082 CA2006 Impact: Obscures full directorship history, enabling identity fragmentation.
Breach Misleading Public Records Section 853L CA2006 Impact: Risks criminal liability for false statements if totals are knowingly inaccurate.
Breach Audit/KYC Failures Section 441 CA2006 Impact: Overdue accounts in dissolved entities may go undetected.
5. Recommendations
Standardize Terminology:
Rename "Total number of appointments" to "Active appointments" or "Historical + Active appointments" for clarity.
Enhance Data Aggregation:
Ensure search results reflect all appointments (active and dissolved) to comply with Section 1082.
System Overhaul:
Fix algorithmic errors causing discrepancies between search results and expanded profiles.
Regulatory Alert:
Notify Companies House of this systemic flaw and request urgent corrective action.
Conclusion
The inconsistent "Total number of appointments" field in Companies House records undermines statutory transparency obligations under the Companies Act 2006. Immediate technical and procedural reforms are required to prevent audit failures, identity fragmentation, and clone company fraud.