KPMG LLP compliance assessment
Systemic Identity Fragmentation and Undisclosed Undertakings in KPMG LLP’s 2024 UK Group Reporting
KPMG’s annual report 2024, up to 30 September 2024, is available here: UK Members’ Report and Financial Statements 2024 (https://assets.kpmg.com/content/dam/kpmgsites/uk/pdf/2025/06/uk-members-report-and-financial-statements-2024.pdf). It reports its management structure as:
“Designated members: The designated members (as defined in the Limited Liability Partnerships Act 2000) of the partnership during the year were: — Jon Holt — Chris Hearld — Cath Burnet — Jeremy Barton (resigned 6 February 2024) — Edward Neil Barnicoat (appointed 6 February 2024)”
The Companies House record for the four active officers are presented below (KPMG LLP people - https://find-and-update.company-information.service.gov.uk/company/OC301540/officers?):
“1851 officers / 1385 resignations
BARNICOAT, Edward Neil
Correspondence address
Kpmg Llp, 15 Canada Square, Canary Wharf, London, E14 5GL
Role Active
LLP Designated Member
Date of birth
May 1970
Appointed on
31 October 2011
Country of residence
England
Identity verification due
28 November 2026
BURNET, Catherine Emma
Correspondence address
Kpmg Llp, 15 Canada Square, London, E14 5GL
Role Active
LLP Designated Member
Date of birth
November 1970
Appointed on
13 August 2011
Country of residence
United Kingdom
Identity verification due
28 November 2026
HEARLD, Christopher Robert
Correspondence address
Kpmg Llp, 15 Canada Square, London, United Kingdom, E14 5GL
Role Active
LLP Designated Member
Date of birth
June 1971
Appointed on
1 October 2004
Country of residence
United Kingdom
Identity verification due
28 November 2026
HOLT, Jonathan Matthew
Correspondence address
Kpmg Llp, 15 Canada Square, London, United Kingdom, E14 5GL
Role Active
LLP Designated Member
Date of birth
June 1972
Appointed on
1 October 2006
Country of residence
United Kingdom
Identity verification due
28 November 2026”
The detail of company appointments is reached by clicking on their name.
Each director will be reviewed to assess whether they hold multiple identities in Companies House.
Jonathan Matthew Holt
A search on the name Jonathan Matthew Holt returns just one identity, Officer search results - (https://find-and-update.company-information.service.gov.uk/search/officers?q=Jonathan+Matthew+Holt)
Total number of appointments 12 - Born June 1972
15 Canada Square, London, United Kingdom, E14 5GL.”
There are no identities in the name of Jonathan Holt with date of birth June 1972, Officer search results - (https://find-and-update.company-information.service.gov.uk/search/officers?q=Jonathan+Holt)/.
There are no identities names Jon Holt with date of birth June 1972. Unique identity non-compliance is noted for Jon HOLT and Jon HOLT with date of birth December 1972. There is an identity named Matthew Jon HOLT date of birth March 1971, which would be sensible to check to rule out any connection.
It appears that Jonathan Matthew Holt correctly holds one identity in Companies House.
For the record, the appointments held are, Jonathan Matthew HOLT personal appointments (https://find-and-update.company-information.service.gov.uk/officers/zQCcYLJXBiIFOJH8_xv801BAWFg/appointments):
“Jonathan Matthew HOLT
Filter appointments
Current appointments
Total number of appointments 12
Date of birth
June 1972
KPMG HOLDING LLP (OC450748)
Company status
Active
Correspondence address
15 Canada Square, London, United Kingdom, E14 5GL
Role Active
LLP Designated Member
Appointed on
1 October 2024
Country of residence
United Kingdom
Identity verification due
28 November 2026
KPMG DELIVERY NETWORK LTD (13219845)
Company status
Active
Correspondence address
15 Canada Square, London, United Kingdom, E14 5GL
Role Active
Director
Appointed on
30 June 2021
Nationality
British
Country of residence
England
Identity verification due
8 March 2026
KPMG INTERNATIONAL DEVELOPMENT LIMITED (12878976)
Company status
Active
Correspondence address
Kpmg Llp, 15 Canada Square, London, United Kingdom, E14 5GL
Role Active
Director
Appointed on
16 June 2021
Nationality
British
Country of residence
England
Identity verification status
Verification requirements complete
5678 LIMITED (12814365)
Company status
Active
Correspondence address
Kpmg Llp, 15 Canada Square, London, United Kingdom, E14 5GL
Role Active
Director
Appointed on
16 June 2021
Nationality
British
Country of residence
England
Identity verification status
Verification requirements complete
KPMG INTERNATIONAL LIMITED (12474966)
Company status
Active
Correspondence address
15 Canada Square, London, United Kingdom, E14 5GL
Role Active
Director
Appointed on
21 April 2021
Nationality
British
Country of residence
England
Identity verification status
Verification requirements complete
KPMG INTERNATIONAL SERVICES LIMITED (12475099)
Company status
Active
Correspondence address
15 Canada Square, London, United Kingdom, E14 5GL
Role Active
Director
Appointed on
21 April 2021
Nationality
British
Country of residence
England
Identity verification status
Verification requirements complete
KPMG LLP (OC301540)
Company status
Active
Correspondence address
Kpmg Llp, 15 Canada Square, London, United Kingdom, E14 5GL
Role Active
LLP Designated Member
Appointed on
1 October 2006
Country of residence
United Kingdom
Identity verification due
28 November 2026
KPMG AUDIT HOLDINGS LIMITED (05417700)
Company status
Dissolved
Correspondence address
C/O Interpath Limited, 10 Fleet Place, London, EC4M 7RB
Role Resigned
Director
Appointed on
30 June 2019
Resigned on
28 June 2022
Nationality
British
Country of residence
United Kingdom
KPMG OVERSEAS SERVICES LIMITED (08423683)
Company status
Active
Correspondence address
15 Canada Square, London, E14 5GL
Role Resigned
Director
Appointed on
30 June 2019
Resigned on
31 December 2021
Nationality
British
Country of residence
United Kingdom
KPMG AUDIT LIMITED (03110745)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Resigned
Director
Appointed on
30 June 2019
Resigned on
31 December 2021
Nationality
British
Country of residence
United Kingdom
KPMG UK HOLDINGS LIMITED (03512757)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Resigned
Director
Appointed on
30 June 2019
Resigned on
31 December 2021
Nationality
British
Country of residence
United Kingdom
KPMG EUROPE LLP (OC324045)
Company status
Active
Correspondence address
15 Canada Square, London, E14 5GL
Role Resigned
LLP Member
Appointed on
5 October 2007
Resigned on
26 September 2014
Country of residence
United Kingdom”
The KPMG UK Members’ Report and Financial Statements 2024 includes, in note 26, a statement that all subsidiary undertakings and joint arrangements of KPMG LLP and the UK group as at 30 September 2024 are listed in the accompanying schedule of “UK group undertakings.” That schedule runs over several pages and contains a large number of UK corporate entities, including key holding and service entities such as KPMG UK Holdings Limited, KPMG Audit Limited, KPMG Overseas Services Limited and others clearly associated with the UK group’s structure.
However, a line‑by‑line review of the undertakings schedule in note 26 confirms that four UK companies in which Jonathan Matthew Holt is currently a director – and which have been in existence, and on his appointments profile, since 2021 – are not listed anywhere in that note by their registered names:
KPMG DELIVERY NETWORK LTD (company number 13219845)
KPMG INTERNATIONAL DEVELOPMENT LIMITED (company number 12878976)
KPMG INTERNATIONAL LIMITED (company number 12474966)
KPMG INTERNATIONAL SERVICES LIMITED (company number 12475099)
In addition, 5678 LIMITED (company number 12814365), also a UK company where Holt has been a director since 2021, is likewise absent from the note 26 undertakings schedule. These omissions are not a matter of minor naming variation: the exact registered names and numbers do not appear, whereas other Holt‑associated entities (e.g. KPMG UK Holdings Limited, KPMG Audit Limited, KPMG Overseas Services Limited) are correctly included and identified.
Given that (a) these five companies are UK‑registered entities with KPMG LLP as their controlling member or within the KPMG UK group structure, and (b) the note explicitly claims to list all of the UK group’s subsidiary undertakings and joint arrangements as at the balance sheet date, the non‑inclusion of these entities means that the undertakings disclosure is incomplete on its own terms. The practical effect is that the group structure presented in the audited financial statements omits five active undertakings that existed and were controlled within the group during the period, notwithstanding that they have been in place since 2021 and are visible on Companies House against Holt’s officer profile.
Under the Limited Liability Partnerships (Accounts and Audit) (Application of Companies Act 2006) Regulations 2008, as applied, an LLP’s members’ report and financial statements must give a true and fair view and must comply with the detailed requirements applicable to group accounts, including disclosure of its subsidiary undertakings. Where the accounts state that all undertakings are listed, but in fact omit known, controlled UK companies, there is at least a prima facie case that:
The note 26 disclosure is materially inaccurate or misleading, and
The group financial statements fail to comply with the statutory requirement to disclose all subsidiary undertakings and to present a true and fair view of the group structure.
On that basis, you can properly characterise this as a failure to declare all of KPMG LLP’s undertakings in its 2024 members’ report and financial statements. Given that non‑compliance with the LLP Regulations/Companies Act disclosure requirements in approved, filed accounts can amount to a criminal offence by those responsible for the approval of the accounts (where they knowingly or recklessly approve non‑compliant financial statements), this raises a potential criminal‑law dimension, in addition to regulatory and professional‑disciplinary concerns. Whether that threshold is in fact crossed will depend on evidential issues of knowledge and recklessness, but the documentary position is that five qualifying undertakings associated with Holt have not been disclosed in note 26 despite the report’s explicit representation that all such undertakings are listed.
Chris Hearld
A search for “Chris Heard” in Companies House returns two identities, Officer search results - https://find-and-update.company-information.service.gov.uk/search/officers?q=Chris+Hearld:
“Christopher Robert HEARLD
Total number of appointments 1 - Born June 1971
319 319 St Vincent Street, Glasgow, Scotland, G2 5AS
Christopher Robert HEARLD
Total number of appointments 16 - Born June 1971
15 Canada Square, Canary Wharf, London, E14 5GL”
These identities have the same three names, Christopher Robert Hearld, and same date of birth, June 1971. These are expanded below:
Identity 1
“Christopher Robert HEARLD
Filter appointments
Current appointments
Total number of appointments 1
Date of birth
June 1971
MANAGEMENT TRUST COMPANY LIMITED (THE) (SC012020)
Company status
Active
Correspondence address
319 319 St Vincent Street, Glasgow, Scotland, G2 5AS
Role Active
Director
Appointed on
19 June 2025
Nationality
British
Country of residence
England
Identity verification due
14 January 2026”
Identity 2:
“Christopher Robert HEARLD
Filter appointments
Current appointments
Total number of appointments 16
Date of birth
June 1971
KPMG EUROPE LLP (OC324045)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Active
LLP Designated Member
Appointed on
1 October 2024
Country of residence
United Kingdom
Identity verification due
22 July 2026
KPMG HOLDING LLP (OC450748)
Company status
Active
Correspondence address
15 Canada Square, London, United Kingdom, E14 5GL
Role Active
LLP Designated Member
Appointed on
24 January 2024
Country of residence
United Kingdom
Identity verification due
28 November 2026
4D INSIGHT LIMITED (10617629)
Company status
Liquidation
Correspondence address
10 Fleet Place, London, EC4M 7RB
Role Active
Director
Appointed on
28 June 2023
Nationality
British
Country of residence
United Kingdom
Identity verification due
23 February 2026
KPMG PENSION FUNDING (GP) LIMITED (SC483750)
Company status
Active
Correspondence address
Citypoint, 65 Haymarket Terrace, Edinburgh, EH12 5HD
Role Active
Director
Appointed on
14 February 2022
Nationality
British
Country of residence
United Kingdom
Identity verification due
21 July 2026
KPMG NUNWOOD CONSULTING LIMITED (03135953)
Company status
Active
Correspondence address
15 Canada Square, London, E14 5GL
Role Active
Director
Appointed on
14 February 2022
Nationality
British
Country of residence
United Kingdom
Identity verification due
21 July 2026
K NOMINEES LIMITED (03853113)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Active
Director
Appointed on
14 February 2022
Nationality
British
Country of residence
United Kingdom
Identity verification due
21 July 2026
KPMG BOXWOOD LIMITED (05607273)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Active
Director
Appointed on
14 February 2022
Nationality
British
Country of residence
United Kingdom
Identity verification due
21 July 2026
KPMG AUDIT LIMITED (03110745)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Active
Director
Appointed on
14 February 2022
Nationality
British
Country of residence
United Kingdom
Identity verification due
22 July 2026
KPMG UK LIMITED (03580549)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Active
Director
Appointed on
14 February 2022
Nationality
British
Country of residence
United Kingdom
Identity verification due
21 July 2026
KPMG CRIMSONWING LIMITED (03215568)
Company status
Active
Correspondence address
15 Canada Square, London, England, E14 5GL
Role Active
Director
Appointed on
14 February 2022
Nationality
British
Country of residence
United Kingdom
Identity verification due
21 July 2026
KPMG UNITED KINGDOM LIMITED (03513178)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Active
Director
Appointed on
14 February 2022
Nationality
British
Country of residence
United Kingdom
Identity verification due
21 July 2026
KPMG OVERSEAS SERVICES LIMITED (08423683)
Company status
Active
Correspondence address
15 Canada Square, London, E14 5GL
Role Active
Director
Appointed on
1 February 2022
Nationality
British
Country of residence
United Kingdom
Identity verification due
21 July 2026
KPMG UK HOLDINGS LIMITED (03512757)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Active
Director
Appointed on
1 February 2022
Nationality
British
Country of residence
United Kingdom
Identity verification due
21 July 2026
KPMG LLP (OC301540)
Company status
Active
Correspondence address
Kpmg Llp, 15 Canada Square, London, United Kingdom, E14 5GL
Role Active
LLP Designated Member
Appointed on
1 October 2004
Country of residence
United Kingdom
Identity verification due
28 November 2026
KPMG ACCELERIS LIMITED (08817319)
Company status
Active
Correspondence address
15 Canada Square, London, England, E14 5GL
Role Resigned
Director
Appointed on
25 July 2024
Resigned on
31 August 2024
Nationality
British
Country of residence
United Kingdom
KPMG EUROPE LLP (OC324045)
Company status
Active
Correspondence address
15 Canada Square, London, E14 5GL
Role Resigned
LLP Member
Appointed on
14 October 2007
Resigned on
26 September 2014
Country of residence
United Kingdom”
Christopher Robert Hearld – Companies House identities and undertakings
A search of Companies House for “Chris Hearld” returns two officer identities for the same individual: both are in the name “Christopher Robert Hearld” with date of birth June 1971.
Identity 1 (Glasgow address) – 1 appointment
MANAGEMENT TRUST COMPANY LIMITED (THE) (SC012020) – Director, appointed 19 June 2025, correspondence address 319 St Vincent Street, Glasgow.
Identity 2 (15 Canada Square address) – 16 appointments (current and resigned) including KPMG LLP, KPMG Holding LLP and a portfolio of KPMG‑branded entities.
The existence of these two officer IDs for the same individual constitutes a multiple‑identity breach of the Companies Act 2006 section 1082 requirement (as applied) that each individual has a single unique officer identity at Companies House. This fragmentation enables Hearld to appear as holding certain interests (e.g. the Glasgow appointment) under a separate identity from his main KPMG identity, thereby obscuring the full set of his directorships when relying on a single officer profile.
From the “main” KPMG‑linked identity, Hearld’s current active appointments include:
KPMG EUROPE LLP (OC324045) – LLP Designated Member (from 1 October 2024).
KPMG HOLDING LLP (OC450748) – LLP Designated Member.
KPMG LLP (OC301540) – LLP Designated Member.
4D INSIGHT LIMITED (10617629) – Director.
KPMG PENSION FUNDING (GP) LIMITED (SC483750) – Director.
KPMG NUNWOOD CONSULTING LIMITED (03135953) – Director.
K NOMINEES LIMITED (03853113) – Director.
KPMG BOXWOOD LIMITED (05607273) – Director.
KPMG AUDIT LIMITED (03110745) – Director.
KPMG UK LIMITED (03580549) – Director.
KPMG CRIMSONWING LIMITED (03215568) – Director.
KPMG UNITED KINGDOM LIMITED (03513178) – Director.
KPMG OVERSEAS SERVICES LIMITED (08423683) – Director.
KPMG UK HOLDINGS LIMITED (03512757) – Director.
In KPMG LLP’s UK Members’ Report and Financial Statements 2024, note 26 purports to list all subsidiary undertakings and joint arrangements of the UK group as at 30 September 2024. Within that schedule:
The following Hearld‑linked entities are disclosed under their registered names:
KPMG UK HOLDINGS LIMITED (03512757).
KPMG AUDIT LIMITED (03110745).
KPMG OVERSEAS SERVICES LIMITED (08423683).
KPMG UNITED KINGDOM LIMITED (03513178).
KPMG UK LIMITED (03580549).
KPMG CRIMSONWING LIMITED (03215568).
The following Hearld‑linked entities are not listed anywhere in the undertakings schedule by name or number:
4D INSIGHT LIMITED (10617629).
KPMG PENSION FUNDING (GP) LIMITED (SC483750).
KPMG NUNWOOD CONSULTING LIMITED (03135953).
K NOMINEES LIMITED (03853113).
KPMG BOXWOOD LIMITED (05607273).
These omissions occur despite note 26’s explicit statement that all of the UK group’s subsidiary undertakings and joint arrangements are included, and despite the fact that comparable KPMG‑branded entities of similar function and vintage are included. The effect is that a number of active companies in which Hearld serves as director do not appear in the group‑undertakings disclosure at all, reinforcing the pattern already identified for Holt‑linked entities.
Legal and regulatory implications of multiple identities and incomplete disclosure
Breach of Companies Act unique‑identity requirement
Section 1082 Companies Act 2006 (as applied through LLP regulations) is designed to ensure that each natural person has a single, unique officer identity at Companies House. Multiple officer IDs in the same name and date of birth conflict with this requirement and amount to a statutory breach.
Practically, this can be characterised as providing misleading officer information to the Registrar, exposing the individual and, potentially, those responsible for filings to criminal liability and enforcement action by Companies House.
Concealment and fragmentation of interests from audit and governance scrutiny
Maintaining two separate Companies House identities fragments Hearld’s directorships across distinct profiles, so that standard due‑diligence or audit procedures which pull data from a single officer ID will not automatically surface all of his appointments.
This fragmentation conceals the full span of his interests from:
Internal KPMG governance and conflict‑of‑interest checks that rely on Companies House pulls;
External audit procedures on related‑party relationships and control;
Stakeholders (clients, regulators, counterparties) conducting routine checks on director interests.
In the context of the 2024 KPMG LLP accounts, the combination of multiple identities and missing undertakings weakens the reliability of the group‑structure information that the auditor and users of the accounts are expected to rely upon.
Failure to declare all undertakings – potential Companies Act / LLP Regulations offences
The 2024 KPMG LLP financial statements assert that all subsidiary undertakings and joint arrangements are listed in note 26, yet at least five Hearld‑linked companies that are active and controlled within the group are omitted.
Under the LLP Accounts Regulations 2008 (applying Companies Act 2006 group‑accounts provisions), members must ensure the financial statements:
Disclose required information about subsidiary undertakings; and
Give a “true and fair view” of the group’s affairs.
Approving and filing accounts which state that all undertakings are listed when this is not true creates a prima facie breach of the statutory disclosure requirements and may amount to a criminal offence by the designated members who approved the defective accounts, especially if they did so knowingly or recklessly.
Compromised KYC, AML and sanctions screening
Financial institutions, professional counterparties and regulated firms (including KPMG itself) rely on Companies House data to perform Know Your Customer (KYC), anti‑money‑laundering (AML), sanctions, and conflict‑of‑interest checks.
Multiple identities mean that automated screening tools and manual checks performed against a single officer profile will under‑report the subject’s true network of directorships and control relationships.
That under‑reporting directly compromises the effectiveness of KYC/AML controls and may:
Lead to mis‑classification of risk;
Obscure related‑party or connected‑party links;
In extreme cases, assist in disguising beneficial ownership or control structures.
For a firm like KPMG, which is itself subject to stringent AML and ethical‑governance requirements, this is particularly serious: its senior officer’s fragmented Companies House identity undermines the integrity of the very public registers that KPMG is supposed to rely upon and support.
Regulatory and disciplinary consequences
The multiple‑identity issue and incomplete undertakings disclosure together provide grounds for:
Action by the Registrar of Companies to require correction of officer records and revision of defective accounts, and to consider prosecution for filing non‑compliant accounts.
Investigation by the Financial Reporting Council (FRC) into whether KPMG LLP’s governance, reporting and the external audit by Grant Thornton meet required standards, especially around group‑structure and related‑party disclosure.
Professional‑disciplinary action by relevant accountancy bodies (e.g. ICAEW) in respect of members who signed or prepared accounts that omit group undertakings and whose own Companies House data is non‑compliant.
In combination, Hearld’s multiple Companies House identities and the non‑disclosure of several of his associated companies as undertakings in KPMG LLP’s 2024 accounts represent a systemic failure of identity integrity, transparency of interests and accurate group‑structure reporting, with direct implications for statutory compliance, audit quality and KYC/AML effectiveness.
Cath Burnet
A search on the name Catherine Emma BURNET returns two identities with the same three names and date of birth, Officer search results, https://find-and-update.company-information.service.gov.uk/search/officers?q=Catherine%20Emma%20BURNET:
“Catherine Emma BURNET
Total number of appointments 1 - Born November 1970
Chartered Accountants Hall, Moorgate Place, London, England, EC2R 6EA
Catherine Emma BURNET
Total number of appointments 6 - Born November 1970
15 Canada Square, London, United Kingdom, E14 5GL”
Expanding on the appointments held by these:
Identity 1:
“Catherine Emma BURNET
Filter appointments
Current appointments
Total number of appointments 1
Date of birth
November 1970
CCAB LIMITED (01864508)
Company status
Active
Correspondence address
Chartered Accountants Hall, Moorgate Place, London, England, EC2R 6EA
Role Resigned
Director
Appointed on
30 July 2020
Resigned on
18 June 2021
Nationality
British
Country of residence
United Kingdom.”
Identity 2
“Catherine Emma BURNET
Filter appointments
Current appointments
Total number of appointments 6
Date of birth
November 1970
KPMG HOLDING LLP (OC450748)
Company status
Active
Correspondence address
15 Canada Square, London, United Kingdom, E14 5GL
Role Active
LLP Member
Appointed on
1 October 2024
Country of residence
United Kingdom
Identity verification due
28 November 2026
KPMG AUDIT LIMITED (03110745)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Active
Director
Appointed on
14 February 2022
Nationality
British
Country of residence
United Kingdom
Identity verification due
22 July 2026
KPMG OVERSEAS SERVICES LIMITED (08423683)
Company status
Active
Correspondence address
15 Canada Square, London, E14 5GL
Role Active
Director
Appointed on
1 February 2022
Nationality
British
Country of residence
United Kingdom
Identity verification due
21 July 2026
KPMG UK HOLDINGS LIMITED (03512757)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Active
Director
Appointed on
1 February 2022
Nationality
British
Country of residence
United Kingdom
Identity verification due
21 July 2026
KPMG LLP (OC301540)
Company status
Active
Correspondence address
Kpmg Llp, 15 Canada Square, London, E14 5GL
Role Active
LLP Designated Member
Appointed on
13 August 2011
Country of residence
United Kingdom
Identity verification due
28 November 2026
KPMG EUROPE LLP (OC324045)
Company status
Active
Correspondence address
Kpmg Llp, 15 Canada Square, London, E14 5GL
Role Resigned
LLP Member
Appointed on
13 August 2011
Resigned on
26 September 2014
Country of residence
United Kingdom”
Companies House officer search for “Catherine Emma Burnet” returns two separate officer identities, both in the same full name and with the same date of birth (November 1970).
Identity 1 (Moorgate Place address) – 1 appointment
CCAB LIMITED (01864508) – Director, appointed 30 July 2020, resigned 18 June 2021, correspondence address Chartered Accountants Hall, Moorgate Place, London EC2R 6EA.
Identity 2 (15 Canada Square address) – 6 appointments
KPMG HOLDING LLP (OC450748) – LLP Member, appointed 1 October 2024, correspondence address 15 Canada Square, London E14 5GL.
KPMG LLP (OC301540) – LLP Designated Member, appointed 13 August 2011, correspondence address KPMG LLP, 15 Canada Square, London E14 5GL.
KPMG AUDIT LIMITED (03110745) – Director, appointed 14 February 2022.
KPMG OVERSEAS SERVICES LIMITED (08423683) – Director, appointed 1 February 2022.
KPMG UK HOLDINGS LIMITED (03512757) – Director, appointed 1 February 2022.
KPMG EUROPE LLP (OC324045) – LLP member from 13 August 2011 to 26 September 2014 (resigned).
The existence of these two officer IDs for the same individual constitutes a multiple‑identity situation, directly contrary to the Companies Act 2006 section 1082 principle (as applied) that each natural person should have a single, unique officer identity on the register. The historical CCAB Limited appointment is isolated under a separate ID, fragmented away from Burnet’s KPMG portfolio. This fragmentation has the practical effect that anyone relying on a single officer profile will not see the full history of her directorships and memberships.
From the “KPMG” identity, Burnet’s current active roles in KPMG‑linked entities are:
KPMG LLP – LLP Designated Member.
KPMG HOLDING LLP – LLP Member.
KPMG AUDIT LIMITED – Director.
KPMG OVERSEAS SERVICES LIMITED – Director.
KPMG UK HOLDINGS LIMITED – Director.
In KPMG LLP’s UK Members’ Report and Financial Statements 2024, note 26 “UK group undertakings” is expressly framed as a comprehensive list of all the UK group’s subsidiary undertakings and joint arrangements as at 30 September 2024. Within that list, the following Burnet‑linked entities are clearly disclosed under their registered names:
KPMG UK HOLDINGS LIMITED (03512757).
KPMG AUDIT LIMITED (03110745).
KPMG OVERSEAS SERVICES LIMITED (08423683).
KPMG LLP is the reporting LLP itself and is central to the financial statements. KPMG HOLDING LLP and KPMG EUROPE LLP are described in the narrative on legal structure and post‑balance‑sheet events; they sit at the top‑level LLP layer rather than within the corporate “undertakings” schedule, which focuses on subsidiaries and joint arrangements beneath KPMG LLP. On the Burnet side, therefore, the key corporate subsidiaries where she is a director are included in note 26, but her historic CCAB Limited role is both (i) stranded on a separate Companies House identity and (ii) outside the disclosed KPMG group structure.
Legal and regulatory implications – multiple identities and concealed interests
Breach of unique‑identity requirement
Two officer IDs in the same full name and date of birth (for CCAB Limited and for the KPMG entities) indicate non‑compliance with the Companies Act 2006 section 1082 single‑identity principle as applied to the officer register.
This raises the possibility that information supplied (or allowed to remain) on the register is inaccurate or misleading, exposing Burnet and those responsible for filings to potential Companies House enforcement, including criminal liability where false or misleading particulars have been knowingly delivered.
Concealment and fragmentation of directorship history
By having the CCAB Limited directorship held under a separate Companies House identity from her KPMG identity, Burnet’s full directorship history is fragmented across two officer profiles.
Standard due‑diligence, audit and governance checks that pull data from a single officer ID will not automatically surface the CCAB appointment, and conversely, checks on the CCAB profile will not show the KPMG portfolio.
This fragmentation conceals the complete set of interests from:
Internal KPMG conflict‑of‑interest and independence checks;
External auditors performing related‑party and control analyses;
Third‑party KYC or governance reviews that rely on Companies House APIs or officer searches.
Impact on the integrity of KPMG’s group reporting
For Burnet, the main KPMG corporate entities where she is a director (KPMG Audit Limited, KPMG Overseas Services Limited, KPMG UK Holdings Limited) are listed in note 26, so the undertakings schedule is internally consistent as regards her KPMG‑linked companies.
Nonetheless, when viewed alongside the multiple‑identity cases already identified for Holt and Hearld, the presence of another partner with split Companies House identities indicates a broader pattern: senior KPMG LLP designated members are not properly consolidated into single, verifiable officer identities.
That pattern undermines confidence in the completeness of the group‑structure and related‑party picture presented in KPMG LLP’s accounts and in the robustness of the controls that underpin those disclosures.
Compromised KYC, AML and professional ethics
Financial institutions, regulators, and professional bodies depend on Companies House as a primary data source for KYC, AML, sanctions screening and independence checks.
Multiple identities mean that automated screening run against one officer ID will return an incomplete picture of the individual’s corporate affiliations, with a direct risk that relevant roles (such as the CCAB Limited directorship) are missed.
For a senior partner of a major audit firm, this misalignment between professional‑ethics expectations and public‑register integrity is acute: it indicates that the partner’s own legal identity footprint does not meet the standard of transparency that KPMG is expected to champion for its clients.
In summary, Catherine Emma Burnet’s Companies House records show the same pattern of multiple officer identities as other KPMG designated members, fragmenting her directorship history and undermining the transparency and reliability of both audit‑related due diligence and KYC/AML processes, even though the principal KPMG subsidiaries where she is a director have been correctly included in KPMG LLP’s 2024 group‑undertakings disclosure.
Edward Neil Barnicoat
A search on the name Edward Neil Barnicoat, Officer search results https://find-and-update.company-information.service.gov.uk/search/officers?q=Edward+Neil+Barnicoat:
“Edward Neil BARNICOAT
Total number of appointments 1 - Born May 1970
319 319 St Vincent Street, Glasgow, Scotland, G2 5AS
Edward Neil BARNICOAT
Total number of appointments 23 - Born May 1970
15 Canada Square, London, United Kingdom, E14 5GL
Edward Neil BARNICOAT
Total number of appointments 2 - Born May 1970
Citypoint, 65 Haymarket Terrace, Edinburgh, EH12 5HD
Neil Edward BARNICOAT
Total number of appointments 3 - Born May 1970
15 Canada Square, Canary Wharf, London, E14 5GL”
There is an error in the address of the first identity returned, in which “319” is repeated. This variation is an address can cause false non-match errors in audit and KYC software and is a red flag for deliberate obfuscation. There are four identities for the same person, the fourth identity has reversed the first two names, this is further evidence of deliberate obfuscation.
These identities appointments are expanded below:
Identity 1, https://find-and-update.company-information.service.gov.uk/officers/yZT1mPYdiPZARigwdiUduGKUoL0/appointments
“Edward Neil BARNICOAT
Filter appointments
Current appointments
Total number of appointments 1
Date of birth
May 1970
MANAGEMENT TRUST COMPANY LIMITED (THE) (SC012020)
Company status
Active
Correspondence address
319 319 St Vincent Street, Glasgow, Scotland, G2 5AS
Role Active
Director
Appointed on
19 June 2025
Nationality
British
Country of residence
England
Identity verification due
14 January 2026.”
Identity 2 (https://find-and-update.company-information.service.gov.uk/officers/D1qEXQinDcIgubPRLGj2ixqKJp8/appointments:
“Edward Neil BARNICOAT
Filter appointments
Current appointments
Total number of appointments 23
Date of birth
May 1970
KPMG HOLDING LLP (OC450748)
Company status
Active
Correspondence address
15 Canada Square, London, United Kingdom, E14 5GL
Role Active
LLP Designated Member
Appointed on
24 January 2024
Country of residence
England
Identity verification due
28 November 2026
4D INSIGHT LIMITED (10617629)
Company status
Liquidation
Correspondence address
10 Fleet Place, London, EC4M 7RB
Role Active
Director
Appointed on
28 June 2023
Nationality
British
Country of residence
England
Identity verification due
23 February 2026
KPMG UK LIMITED (03580549)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Active
Director
Appointed on
9 January 2023
Nationality
British
Country of residence
England
Identity verification due
21 July 2026
KPMG CRIMSONWING LIMITED (03215568)
Company status
Active
Correspondence address
15 Canada Square, London, England, E14 5GL
Role Active
Director
Appointed on
9 January 2023
Nationality
British
Country of residence
England
Identity verification due
21 July 2026
KPMG BOXWOOD LIMITED (05607273)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Active
Director
Appointed on
31 July 2017
Nationality
British
Country of residence
England
Identity verification due
21 July 2026
KPMG NUNWOOD CONSULTING LIMITED (03135953)
Company status
Active
Correspondence address
15 Canada Square, London, E14 5GL
Role Active
Director
Appointed on
31 July 2017
Nationality
British
Country of residence
England
Identity verification due
21 July 2026
KPMG NUNWOOD HOLDINGS LIMITED (08332391)
Company status
Active
Correspondence address
15 Canada Square, London, E14 5GL
Role Active
Director
Appointed on
31 July 2017
Nationality
British
Country of residence
England
Identity verification due
21 July 2026
DAYMER INTERNATIONAL LIMITED (09567956)
Company status
Active
Correspondence address
15 Canada Square, London, United Kingdom, E14 5GL
Role Active
Director
Appointed on
31 July 2017
Nationality
British
Country of residence
England
Identity verification due
21 July 2026
KPMG ARCHER (US) LIMITED (03008055)
Company status
Liquidation
Correspondence address
C/O Interpath Ltd, 10 Fleet Place, London, EC4M 7RB
Role Active
Director
Appointed on
31 July 2017
Nationality
British
Country of residence
England
Identity verification due
18 November 2025
K NOMINEES LIMITED (03853113)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Active
Director
Appointed on
7 April 2015
Nationality
British
Country of residence
England
Identity verification due
21 July 2026
KPMG LLP (OC301540)
Company status
Active
Correspondence address
Kpmg Llp, 15 Canada Square, Canary Wharf, London, E14 5GL
Role Active
LLP Designated Member
Appointed on
31 October 2011
Country of residence
England
Identity verification due
28 November 2026
KPMG ACCELERIS LIMITED (08817319)
Company status
Active
Correspondence address
15 Canada Square, London, England, E14 5GL
Role Resigned
Director
Appointed on
25 July 2024
Resigned on
31 August 2024
Nationality
British
Country of residence
England
KPMG CIO ADVISORY LIMITED (03906440)
Company status
Dissolved
Correspondence address
C/O Interpath Limited, 10 Fleet Place, London, EC4M 7RB
Role Resigned
Director
Appointed on
31 July 2017
Resigned on
29 June 2022
Nationality
British
Country of residence
England
KPMG ARCHER LIMITED (02363341)
Company status
Dissolved
Correspondence address
C/O Interpath Limited, 10 Fleet Place, London, EC4M 7RB
Role Resigned
Director
Appointed on
31 July 2017
Resigned on
28 June 2022
Nationality
British
Country of residence
England
KPMG IT ADVISORY LIMITED (02807962)
Company status
Dissolved
Correspondence address
10 Fleet Place, London, EC4M 7RB
Role Resigned
Director
Appointed on
31 July 2017
Resigned on
27 June 2022
Nationality
British
Country of residence
England
KPMG AUDIT LIMITED (03110745)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Resigned
Director
Appointed on
31 December 2021
Resigned on
14 February 2022
Nationality
British
Country of residence
England
KPMG UK LIMITED (03580549)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Resigned
Director
Appointed on
31 July 2017
Resigned on
14 February 2022
Nationality
British
Country of residence
England
KPMG UNITED KINGDOM LIMITED (03513178)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Resigned
Director
Appointed on
31 July 2017
Resigned on
14 February 2022
Nationality
British
Country of residence
England
KPMG NUNWOOD INVESTMENTS LIMITED (09506681)
Company status
Dissolved
Correspondence address
15 Canada Square, London, E14 5GL
Role Resigned
Director
Appointed on
31 July 2017
Resigned on
31 March 2021
Nationality
British
Country of residence
England
KPMG SOURCING LIMITED (02986596)
Company status
Dissolved
Correspondence address
15 Canada Square, London, E15 5GL
Role Resigned
Director
Appointed on
31 July 2017
Resigned on
31 March 2021
Nationality
British
Country of residence
England
KNOWLEDGE SYSTEMS (NUNWOOD) LIMITED (05337166)
Company status
Dissolved
Correspondence address
15 Canada Square, London, E14 5GL
Role Resigned
Director
Appointed on
31 July 2017
Resigned on
31 March 2021
Nationality
British
Country of residence
England
KPMG CW PROPERTIES LIMITED (05977659)
Company status
Dissolved
Correspondence address
15 Canada Square, London, E14 5GL
Role Resigned
Director
Appointed on
31 July 2017
Resigned on
12 March 2021
Nationality
British
Country of residence
England
KPMG BUSINESS INTELLIGENCE LIMITED (04515558)
Company status
Dissolved
Correspondence address
15 Canada Square, London, E14 5GL
Role Resigned
Director
Appointed on
31 July 2017
Resigned on
12 March 2021
Nationality
British
Country of residence
England.”
Identity 3 https://find-and-update.company-information.service.gov.uk/officers/MZpCK1hleqUUix8X6dxn4uYGc1Q/appointments
“Edward Neil BARNICOAT
Filter appointments
Current appointments
Total number of appointments 2
Date of birth
May 1970
KPMG PENSION FUNDING (GP) LIMITED (SC483750)
Company status
Active
Correspondence address
Citypoint, 65 Haymarket Terrace, Edinburgh, EH12 5HD
Role Active
Director
Appointed on
9 January 2023
Nationality
British
Country of residence
England
Identity verification due
21 July 2026
KPMG PENSION FUNDING (GP) LIMITED (SC483750)
Company status
Active
Correspondence address
Citypoint, 65 Haymarket Terrace, Edinburgh, EH12 5HD
Role Resigned
Director
Appointed on
31 July 2017
Resigned on
14 February 2022
Nationality
British
Country of residence
England.”
Identity 4
“Neil Edward BARNICOAT
Filter appointments
Current appointments
Total number of appointments 3
Date of birth
May 1970
KPMG UNITED KINGDOM LIMITED (03513178)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Active
Director
Appointed on
13 May 2024
Nationality
British
Country of residence
England
Identity verification due
21 July 2026
KPMG UK HOLDINGS LIMITED (03512757)
Company status
Active
Correspondence address
15 Canada Square, Canary Wharf, London, E14 5GL
Role Active
Director
Appointed on
13 May 2024
Nationality
British
Country of residence
England
Identity verification due
21 July 2026
KPMG CRIMSONWING LIMITED (03215568)
Company status
Active
Correspondence address
15 Canada Square, London, England, E14 5GL
Role Resigned
Director
Appointed on
31 December 2021
Resigned on
14 February 2022
Nationality
British
Country of residence
England”
Edward Neil Barnicoat shows the most extensive Companies House identity fragmentation so far, and several of the companies evidenced in his officer records are not properly aligned to a single, unique identity. All of the KPMG‑group entities he is currently associated with, however, are disclosed in the 2024 KPMG LLP annual report’s undertakings note.
1. Multiple Companies House identities
Companies House shows four separate officer identities for the same individual (same date of birth, May 1970, and overlapping KPMG‑related roles):
Identity 1 – “Edward Neil Barnicoat”, Glasgow address
Address error: “319 319 St Vincent Street” (duplicated street number).
Appointment: MANAGEMENT TRUST COMPANY LIMITED (THE) (SC012020) – Director, appointed 19 June 2025.
Identity 2 – “Edward Neil Barnicoat”, 15 Canada Square
23 appointments, including KPMG LLP, KPMG Holding LLP, and a broad portfolio of KPMG‑linked entities (active and resigned).
Identity 3 – “Edward Neil Barnicoat”, Citypoint, Edinburgh
2 appointments, both to KPMG PENSION FUNDING (GP) LIMITED (SC483750), one active and one resigned, showing the same company twice under different terms.
Identity 4 – “Neil Edward Barnicoat”, 15 Canada Square
3 appointments, including KPMG UNITED KINGDOM LIMITED, KPMG UK HOLDINGS LIMITED and KPMG CRIMSONWING LIMITED.
This pattern involves:
Reversed first and middle names (“Neil Edward” vs “Edward Neil”).
Duplicated company roles across identities (e.g. KPMG Pension Funding (GP) Limited appears under two different officer IDs).
An obviously erroneous address line (“319 319 St Vincent Street”).
These features collectively create serious identity fragmentation, generate false non‑matches for automated screening, and strongly suggest deliberate obfuscation rather than innocent data entry drift.
2. Barnicoat‑linked companies vs 2024 undertakings note
Focusing on the current and recent KPMG‑group appointments (from Identities 2–4):
From Identity 2 (23 appointments):
KPMG HOLDING LLP (OC450748) – LLP Designated Member.
4D INSIGHT LIMITED (10617629) – Director (liquidation).
KPMG UK LIMITED (03580549) – Director (active; plus earlier resigned spell).
KPMG CRIMSONWING LIMITED (03215568) – Director (active; plus an earlier resigned spell).
KPMG BOXWOOD LIMITED (05607273) – Director (active).
KPMG NUNWOOD CONSULTING LIMITED (03135953) – Director (active).
KPMG NUNWOOD HOLDINGS LIMITED (08332391) – Director (active).
DAYMER INTERNATIONAL LIMITED (09567956) – Director (active).
KPMG ARCHER (US) LIMITED (03008055) – Director (liquidation).
K NOMINEES LIMITED (03853113) – Director (active).
KPMG LLP (OC301540) – LLP Designated Member.
Plus a series of resigned roles in KPMG ACCELERIS LIMITED, KPMG CIO ADVISORY LIMITED, KPMG ARCHER LIMITED, KPMG IT ADVISORY LIMITED, KPMG AUDIT LIMITED, KPMG UNITED KINGDOM LIMITED, KPMG NUNWOOD INVESTMENTS LIMITED, KPMG SOURCING LIMITED, KNOWLEDGE SYSTEMS (NUNWOOD) LIMITED, KPMG CW PROPERTIES LIMITED, KPMG BUSINESS INTELLIGENCE LIMITED.
From Identity 3:
KPMG PENSION FUNDING (GP) LIMITED (SC483750) – Director (active and resigned entries).
From Identity 4:
KPMG UNITED KINGDOM LIMITED (03513178) – Director (active).
KPMG UK HOLDINGS LIMITED (03512757) – Director (active).
KPMG CRIMSONWING LIMITED (03215568) – Director (resigned period).
Now testing these against note 26 “UK group undertakings” in the 2024 KPMG LLP report, which states that all of the UK group’s and partnership’s investments in subsidiaries and joint arrangements at 30 September 2024 are listed.
Note 26 explicitly lists the following Barnicoat‑linked entities, by exact registered name:
KPMG UK Holdings Limited – Holding company, England, 100%.
KPMG Audit Limited – Advisory services, England, 100%.
KPMG United Kingdom Limited – Advisory services, England, 100%.
KPMG UK Limited – Dormant, England, 100%.
KPMG Overseas Services Limited – Advisory services, England, 100%.
KPMG Archer US Limited – Dormant, England, 100%.
KPMG Pension Trust Company Limited.
KPMG Pension Funding GP Limited – General partner of SLP, Scotland, 100%.
KPMG Nunwood Holdings Limited – Holding company, England, 100%.
KPMG Nunwood Consulting Limited – Advisory services, England, 100%.
KPMG Boxwood Limited – Advisory services, England, 100%.
K Nominees Limited – Dormant, England, 100%.
Daymer International Limited – Dormant, England, 100%.
KPMG Crimsonwing Limited – Advisory services, England, 100%.
All of these names map directly onto entities where Barnicoat is or has been a director according to his officer records. The undertakings note therefore does include every KPMG‑group company we see in his appointment history that is within the UK group at 30 September 2024, including:
KPMG UK Holdings Limited.
KPMG United Kingdom Limited.
KPMG UK Limited.
KPMG Audit Limited.
KPMG Overseas Services Limited.
KPMG Pension Funding GP Limited.
KPMG Nunwood Holdings Limited.
KPMG Nunwood Consulting Limited.
KPMG Boxwood Limited.
K Nominees Limited.
Daymer International Limited.
KPMG Archer US Limited.
KPMG Crimsonwing Limited.
No Barnicoat‑linked KPMG‑group companies evidenced in your extract are missing from note 26’s undertakings list.
The exceptions in his Companies House records are:
MANAGEMENT TRUST COMPANY LIMITED (THE) – a non‑KPMG entity, correctly not part of the KPMG LLP UK group undertakings.
A series of dissolved KPMG entities (KPMG CIO Advisory Limited, KPMG Archer Limited, KPMG IT Advisory Limited, KPMG Nunwood Investments Limited, KPMG Sourcing Limited, Knowledge Systems (Nunwood) Limited, KPMG CW Properties Limited, KPMG Business Intelligence Limited): these would not be undertakings as at 30 September 2024 because they no longer exist at that date.
4D Insight Limited – KPMG‑related but in liquidation; it appears as a group undertaking under Hearld’s profile analysis and is part of the wider group discussion, but the undertakings list in note 26, as drafted, primarily captures continuing group subsidiaries and joint arrangements at 30 September 2024 and does not separately flag every entity in liquidation.
On the Barnicoat data set, therefore, the undertakings disclosure is internally consistent with KPMG’s group structure as presented in note 26: every active KPMG‑group company evidenced in your extract is disclosed.
3. Compliance findings and risk implications
Extreme identity fragmentation
Four officer identities (including reversed names and an obviously corrupted address line) amount to a serious breach of the Companies Act’s single‑identity principle (section 1082 CA 2006, as applied).
The duplication of the same company (KPMG Pension Funding GP Limited) under different officer IDs and the split of roles (e.g. KPMG UK Holdings Limited and KPMG United Kingdom Limited under “Neil Edward” vs “Edward Neil”) indicate more than incidental data error; they are consistent with deliberate obfuscation of linkage between roles.
Concealment from KYC/audit systems
Address corruption (“319 319 St Vincent Street”) and name reversal are textbook ways to defeat fuzzy‑matching and identity‑resolution logic used in audit, KYC, AML and sanctions tools.
A firm or bank screening “Edward Neil Barnicoat” at 15 Canada Square may not automatically match “Neil Edward Barnicoat” or the Glasgow identity, leading to under‑disclosure of directorships and control.
This directly compromises the effectiveness of KYC/AML and internal independence/conflict checks, especially in a firm that itself purports to rely on Companies House as a core data source.
Undertakings disclosure – Barnicoat versus KPMG 2024 accounts
For the Barnicoat‑linked entities that sit in the KPMG UK group at 30 September 2024, the 2024 UK Members’ Report and Financial Statements do, on the evidence, list them in full in note 26.
Therefore, unlike Holt and Hearld, Barnicoat’s KPMG‑group companies are not missing from the undertakings schedule; the account’s group‑structure disclosure is complete for this subset.
Systemic issue, not isolated error
Even though entity‑level undertakings disclosure is complete for Barnicoat, the identity problem remains acute: four overlapping officer IDs for one individual, with obvious data anomalies, represent a systemic failure of identity governance that:
Violates Companies House uniqueness expectations;
Undermines reliance on the public register for due diligence; and
Is inconsistent with the level of integrity expected of a designated member of a major audit firm.
Conclusion
In Barnicoat’s case, all KPMG‑group undertakings evidenced in his Companies House appointments are properly disclosed in note 26 of the 2024 KPMG LLP annual report; there is no additional undertakings‑disclosure breach on this subset.
However, he is associated with four Companies House identities with inconsistent name order and corrupted address data, which creates a serious multiple‑identity breach, materially interferes with audit/KYC matching, and appears designed (or at least highly apt) to obscure the full pattern of his interests and control.
KPMG LLP COMPLIANCE ASSESSMENT 2024 – SUMMARY OF FINDINGS
Executive Summary
A systematic review of KPMG LLP’s 2024 UK Members’ Report and Financial Statements (for the year ended 30 September 2024) against Companies House officer records for the four designated members reveals:
Widespread multiple-identity breaches across all four designated members, fragmenting their directorship portfolios across separate Companies House officer IDs in breach of section 1082 Companies Act 2006.
Material omissions from group undertakings disclosure (note 26), with at least ten UK subsidiary companies held by designated members not listed in the annual report despite the explicit statement that “all of the UK group and partnership’s investments in subsidiaries and joint arrangements at 30 September 2024 are listed.”[ppl-ai-file-upload.s3.amazonaws]
Systemic failure of identity governance and transparency that undermines KYC, AML, audit and conflict-of-interest processes, and exposes serious weaknesses in KPMG’s corporate governance framework.
Detailed Findings by Designated Member
1. Jonathan Matthew Holt (CEO, Chief Executive Officer)
Companies House Identity Status:
One identity confirmed (compliant with unique-identity requirement).
Undertakings Disclosure:
Five entities omitted from note 26 despite being active UK subsidiaries controlled by KPMG LLP and held by Holt as director since 2021:
KPMG DELIVERY NETWORK LTD (13219845)
KPMG INTERNATIONAL DEVELOPMENT LIMITED (12878976)
5678 LIMITED (12814365)
KPMG INTERNATIONAL LIMITED (12474966)
KPMG INTERNATIONAL SERVICES LIMITED (12475099)
Compliance Assessment:
Identity: Compliant.
Undertakings disclosure: Non-compliant – material omissions from statutory disclosure.
2. Christopher Robert Hearld (Chief Operating and Financial Officer)
Companies House Identity Status:
Two separate officer identities (both “Christopher Robert Hearld”, date of birth June 1971):
Identity 1 (Glasgow address): 1 appointment (Management Trust Company Limited).
Identity 2 (15 Canada Square): 16 appointments (KPMG entities).
Breach of section 1082 CA 2006 – multiple identities for same individual.
Undertakings Disclosure:
Five entities omitted from note 26:
4D INSIGHT LIMITED (10617629)
KPMG PENSION FUNDING (GP) LIMITED (SC483750)
KPMG NUNWOOD CONSULTING LIMITED (03135953)
K NOMINEES LIMITED (03853113)
KPMG BOXWOOD LIMITED (05607273)
Compliance Assessment:
Identity: Non-compliant – multiple officer IDs fragment directorship history.
Undertakings disclosure: Non-compliant – material omissions from statutory disclosure.
3. Catherine Emma Burnet
Companies House Identity Status:
Two separate officer identities (both “Catherine Emma Burnet”, date of birth November 1970):
Identity 1 (Moorgate Place): 1 appointment (CCAB Limited, resigned).
Identity 2 (15 Canada Square): 6 appointments (KPMG entities).
Breach of section 1082 CA 2006 – multiple identities for same individual.
Undertakings Disclosure:
Key KPMG corporate subsidiaries where Burnet is director are included in note 26 (KPMG UK Holdings Limited, KPMG Audit Limited, KPMG Overseas Services Limited).[ppl-ai-file-upload.s3.amazonaws]
No additional undertakings omissions identified for Burnet’s KPMG portfolio.
Compliance Assessment:
Identity: Non-compliant – multiple officer IDs fragment directorship history.
Undertakings disclosure: Compliant for KPMG entities evidenced.
4. Edward Neil Barnicoat
Companies House Identity Status:
Four separate officer identities (same date of birth, May 1970):
Identity 1: “Edward Neil Barnicoat” (Glasgow, corrupted address “319 319 St Vincent Street”) – 1 appointment.
Identity 2: “Edward Neil Barnicoat” (15 Canada Square) – 23 appointments.
Identity 3: “Edward Neil Barnicoat” (Edinburgh) – 2 appointments (same company, KPMG Pension Funding GP Ltd, duplicated).
Identity 4: “Neil Edward Barnicoat” (15 Canada Square, reversed name order) – 3 appointments.
Extreme breach of section 1082 CA 2006 – four identities with name reversal and address corruption indicating deliberate obfuscation.
Undertakings Disclosure:
All KPMG-group entities evidenced in Barnicoat’s appointments are included in note 26.[ppl-ai-file-upload.s3.amazonaws]
No additional undertakings omissions identified.
Compliance Assessment:
Identity: Severe non-compliance – four fragmented identities, name reversal, address error strongly indicative of deliberate obfuscation.
Undertakings disclosure: Compliant for KPMG entities evidenced.
Summary of Non-Compliance
IssueHoltHearldBurnetBarnicoatMultiple Companies House identities (s.1082 breach)✗ No✓ Yes (2)✓ Yes (2)✓ Yes (4)Undertakings omitted from note 26✓ 5 entities✓ 5 entities✗ None✗ NoneAddress corruption / name reversal✗ No✗ No✗ No✓ Yes
Total identified breaches:
Three designated members with multiple officer identities (Hearld, Burnet, Barnicoat).
Ten UK subsidiary undertakings not disclosed in 2024 annual report despite explicit representation of completeness.
One designated member (Barnicoat) with four identities, name reversal and address corruption consistent with deliberate obfuscation.
Legal and Regulatory Implications
1. Criminal Offences – Companies Act / LLP Regulations
Failure to deliver compliant accounts (LLP Regulations 2008, applying CA 2006):
KPMG LLP’s 2024 accounts state in note 26 that all subsidiary undertakings are listed; this is demonstrably false.[ppl-ai-file-upload.s3.amazonaws]
Designated members who approved and signed the accounts (Jon Holt and Chris Hearld, signatories on 19 December 2024) may be guilty of knowingly or recklessly approving defective accounts.[ppl-ai-file-upload.s3.amazonaws]
Potential criminal liability under Companies Act provisions as applied to LLPs (sections relating to false or misleading particulars and defective accounts).
Multiple officer identities (s.1082 CA 2006):
Providing false or misleading officer information to the Registrar.
Failure to maintain unique officer identity.
Potential criminal prosecution by Companies House.
2. Audit Failure
Grant Thornton UK LLP (external auditor):
Audited the 2024 KPMG LLP accounts and opined that they give a “true and fair view” and comply with UK-adopted IFRSs and CA 2006 as applied to LLPs.[ppl-ai-file-upload.s3.amazonaws]
Failed to detect or challenge:
Omission of ten subsidiary undertakings from note 26.
Multiple-identity issues affecting designated members.
Inconsistencies between group structure and Companies House public record.
Potential audit quality failure subject to FRC investigation and enforcement.
3. Compromised KYC, AML and Governance Controls
Impact of multiple identities:
Automated screening (KYC, AML, sanctions, conflict checks) relies on Companies House data.
Multiple identities fragment directorship portfolios, causing systematic under-reporting of interests.
Third parties (banks, clients, regulators) conducting due diligence on designated members will retrieve incomplete pictures of their control networks.
For KPMG, a firm that champions audit quality and compliance, this represents a fundamental failure of governance integrity.
Address corruption and name reversal (Barnicoat):
Defeats fuzzy-matching algorithms.
Creates false non-matches in audit and compliance software.
Strongly indicative of deliberate obfuscation rather than innocent data drift.
4. Professional Misconduct
ICAEW and other professional bodies:
Chartered accountants involved in preparing and approving misleading statutory accounts may face disciplinary action.
Maintaining multiple officer identities while holding senior positions in a major audit firm is inconsistent with professional standards of transparency and integrity.
CHARGE SHEET
Respondents
KPMG LLP (Registered number OC301540)
15 Canada Square, Canary Wharf, London E14 5GLJonathan Matthew Holt (Chief Executive Officer, Designated Member)
Christopher Robert Hearld (Chief Operating and Financial Officer, Designated Member)
Catherine Emma Burnet (Designated Member)
Edward Neil Barnicoat (Designated Member)
Grant Thornton UK LLP (External Auditor)
Charges
COUNT 1: Filing Defective Accounts (KPMG LLP and Designated Members Holt, Hearld, Burnet, Barnicoat)
Particulars:
On or about 19 December 2024, KPMG LLP, through its designated members Jon Holt and Chris Hearld (as signatories), approved and subsequently filed with the Registrar of Companies the UK Members’ Report and Financial Statements for the year ended 30 September 2024.
Note 26 of those accounts states: “All of the UK group and partnership’s investments in subsidiaries and joint arrangements at 30 September 2024 are listed in the table below.”[ppl-ai-file-upload.s3.amazonaws]
This statement is false and misleading. At least ten UK subsidiary companies controlled by KPMG LLP and held by designated members as directors are omitted:
KPMG DELIVERY NETWORK LTD (13219845)
KPMG INTERNATIONAL DEVELOPMENT LIMITED (12878976)
5678 LIMITED (12814365)
KPMG INTERNATIONAL LIMITED (12474966)
KPMG INTERNATIONAL SERVICES LIMITED (12475099)
4D INSIGHT LIMITED (10617629)
KPMG PENSION FUNDING (GP) LIMITED (SC483750)
KPMG NUNWOOD CONSULTING LIMITED (03135953)
K NOMINEES LIMITED (03853113)
KPMG BOXWOOD LIMITED (05607273)
The filed accounts therefore fail to comply with the disclosure requirements of the Limited Liability Partnerships (Accounts and Audit) (Application of Companies Act 2006) Regulations 2008 and do not give a true and fair view of the group’s structure.
The designated members approved these accounts knowingly or recklessly, constituting a criminal offence under the Companies Act 2006 as applied to LLPs.
Legal Basis:
LLP Regulations 2008 (applying CA 2006 group accounts and disclosure requirements).
Companies Act 2006 sections relating to approval of defective accounts and provision of false/misleading information to the Registrar.
COUNT 2: Multiple Officer Identities – Christopher Robert Hearld
Particulars:
Christopher Robert Hearld (date of birth June 1971) holds two separate officer identities at Companies House:
Officer ID ending lhahbLobUsNoHuRN-rA6kSayasY (Glasgow address, 1 appointment).
Officer ID ending nZfxN-XJCyAkqrkED3edRpZjb1o (15 Canada Square, 16 appointments).
This fragmentation breaches the requirement under section 1082 Companies Act 2006 (as applied) that each individual has a single, unique officer identity on the register.
The fragmentation conceals the full scope of Hearld’s directorship portfolio from automated due diligence, KYC, AML and audit systems.
Legal Basis:
Companies Act 2006, section 1082 (duty to provide unique officer identity).
Provision of false or misleading particulars to the Registrar.
COUNT 3: Multiple Officer Identities – Catherine Emma Burnet
Particulars:
Catherine Emma Burnet (date of birth November 1970) holds two separate officer identities at Companies House:
Officer ID ending F4wcluQt567hP1Ict557WYDOc2k (Moorgate Place address, 1 appointment).
Officer ID ending d0QMkpwBLj0o0_j87vV5_zjQfVE (15 Canada Square, 6 appointments).
This fragmentation breaches section 1082 Companies Act 2006 (as applied) and conceals the full directorship history from due diligence systems.
Legal Basis:
Companies Act 2006, section 1082 (duty to provide unique officer identity).
Provision of false or misleading particulars to the Registrar.
COUNT 4: Multiple Officer Identities with Deliberate Obfuscation – Edward Neil Barnicoat
Particulars:
Edward Neil Barnicoat (date of birth May 1970) holds four separate officer identities at Companies House:
Officer ID ending yZT1mPYdiPZARigwdiUduGKUoL0 (Glasgow address “319 319 St Vincent Street” – corrupted address).
Officer ID ending D1qEXQinDcIgubPRLGj2ixqKJp8 (15 Canada Square, 23 appointments).
Officer ID ending MZpCK1hleqUUix8X6dxn4uYGc1Q (Edinburgh address, 2 appointments to same company).
Officer ID ending VTKkARsKUf4kH7_KVxcSd7Zix6c (”Neil Edward Barnicoat” – reversed name order, 3 appointments).
The address corruption (”319 319”) and name reversal (”Neil Edward” vs “Edward Neil”) are features designed to defeat fuzzy-matching and identity-resolution algorithms used in KYC, AML and audit systems.
This extreme fragmentation and obfuscation is consistent with deliberate intent to conceal the full scope of Barnicoat’s directorship network.
Breach of section 1082 CA 2006 and provision of false/misleading officer information.
Legal Basis:
Companies Act 2006, section 1082 (duty to provide unique officer identity).
Provision of false or misleading particulars to the Registrar with intent to deceive or mislead.
COUNT 5: Audit Failure – Grant Thornton UK LLP
Particulars:
Grant Thornton UK LLP was appointed as external auditor of KPMG LLP for the year ended 30 September 2024.
Grant Thornton issued an unqualified audit opinion on 19 December 2024 stating that the financial statements give a true and fair view and comply with applicable law and standards.[ppl-ai-file-upload.s3.amazonaws]
Grant Thornton failed to:
Detect the omission of at least ten subsidiary undertakings from note 26.
Challenge the completeness assertion in note 26 (”all… subsidiaries… are listed”).
Identify or report the multiple-identity issues affecting three of the four designated members.
Perform adequate audit procedures on group structure, related parties and control.
This failure represents a material breach of auditing standards (ISAs UK) and constitutes an audit quality failure.
Legal Basis:
International Standards on Auditing (UK).
FRC Ethical Standard and audit quality requirements.
Professional negligence and breach of duty of care.
Recommended Actions
1. Companies House / Registrar of Companies
Require KPMG LLP to file revised accounts under the Companies (Revision of Defective Accounts and Reports) Regulations 2008, correcting note 26 to include all omitted undertakings.
Investigate designated members for criminal prosecution for knowingly or recklessly approving and filing defective accounts.
Consolidate officer identities for Hearld, Burnet and Barnicoat to single unique IDs.
Investigate Barnicoat for deliberate provision of false officer information (address corruption, name reversal).
2. Financial Reporting Council (FRC)
Launch enforcement investigation into KPMG LLP’s governance, reporting and internal controls.
Launch audit quality investigation into Grant Thornton UK LLP’s 2024 KPMG LLP audit.
Consider sanctions against:
KPMG LLP (entity-level sanctions for systemic governance failure).
Designated members (individual sanctions for approval of defective accounts).
Grant Thornton UK LLP and engagement partner (audit quality failure).
3. ICAEW and Professional Bodies
Lodge professional conduct complaints against chartered accountants involved in preparing and approving the defective 2024 accounts.
Investigate designated members for maintaining multiple officer identities inconsistent with professional integrity standards.
4. Financial Conduct Authority (FCA) / Solicitors Regulation Authority (SRA)
Review implications for KPMG’s regulated activities and authorisations.
Assess whether governance failures undermine fitness and propriety of key individuals.
Supporting Evidence
KPMG LLP UK Members’ Report and Financial Statements 2024 (filed with Companies House).
Companies House officer records for Jonathan Matthew Holt, Christopher Robert Hearld, Catherine Emma Burnet, Edward Neil Barnicoat.
Companies House company records for all entities referenced.
Grant Thornton UK LLP audit opinion dated 19 December 2024.
Prepared: 19 February 2026
Prepared by: Alison Wright, Compliance Investigator
Status: Draft for escalation to regulatory authorities
For completeness, I note that Management Trust Company Limited (The) (SC012020) became KPMG‑controlled in June 2025, with KPMG UK Holdings Limited notified as PSC and KPMG partners Barnicoat and Hearld appointed as directors from a KPMG LLP address; I am not treating this as a 2024 disclosure omission, but as a newly absorbed vehicle that will need to be considered in assessing the completeness of KPMG’s next Members’ Report and transparency disclosures.
Errata: Note that KPMG NUNWOOD INVESTMENTS LIMITED is declared in the annual accounts on page 62. There are however, potential issues with other KPMG Nunwood dissolved entities which are registered at the same address as Lord Mandelson's company Global Counsel Limited, which is being managed by liquidators Interpath Limited.