An RTM (Right to Manage) company or an RMC (Residents' Management Company) is, legally, an ordinary limited company registered at Companies House — usually limited by guarantee rather than by shares, but a company all the same. That means it carries the exact same statutory filing obligations as any other UK company, on top of everything else the directors are already juggling: service charges, maintenance, insurance renewals, and the AGM.
This is specifically about buildings where a company sits between the owners and the right to manage — the RTM/RMC structure most common in England & Wales. It doesn't apply to the typical Scottish factor arrangement, where the factor operates directly under the building's title deeds and the Tenements (Scotland) Act 2004, with no company registered at Companies House in between.
It's an easy thing to lose track of. Unlike a service charge demand or an insurance renewal, there's no invoice landing in the post to remind you a Confirmation Statement or a set of accounts is due — and because the company usually isn't trading for profit, it's tempting to assume the normal company filing rules don't really apply. They do.
Every RTM or RMC company has two recurring obligations at Companies House, regardless of whether the building had an eventful year or not.
The Confirmation Statement. This is a yearly snapshot confirming the company's core details are still accurate — registered office, directors, and who the shareholders or guarantee members are (in most RTM/RMC companies, that's the leaseholders themselves). It's due once every 12 months, with a 14-day window after the review period ends to actually file it, and costs £50 to submit online. Even if literally nothing has changed since last year, it still has to be filed — "nothing changed" is itself a valid confirmation, but it isn't automatic.
Annual accounts. Separately, the company has to file accounts each year. Many RTM and RMC companies qualify to file as dormant, since service charge money is typically held on trust for leaseholders rather than counted as the company's own income or profit — but whether that applies to your specific company depends on how it's structured and how funds are actually held, and it's worth confirming with an accountant rather than assuming. Dormant or not, the filing itself is still mandatory.
The two filings carry different consequences if they slip, and it's worth knowing the difference rather than assuming the worst (or the best) about either.
Confirmation Statement: there's no automatic banded fine simply for filing late — but that doesn't mean it's harmless. Since the 2024 Economic Crime and Corporate Transparency Act reforms, Companies House now has the power to issue a civil penalty (up to £5,000) for failing to file, on top of the older risk of strike-off. In practice, the real danger isn't a bill landing on the doormat — it's the company quietly being marked overdue on the public register, then a warning notice, and if that's ignored for long enough, a strike-off notice published in the Gazette. From there it's roughly a two-month objection window before the company can actually be dissolved — so the whole process from missed deadline to dissolution typically plays out over four to five months, not overnight, but it is a real deadline with a real end point.
Annual accounts: this one does carry an automatic, banded late filing penalty, starting at £150 for a private company filing up to one month late and rising to £1,500 for more than six months late — charged regardless of whether the accounts show any activity at all.
Either filing left unresolved for long enough can lead to the company being struck off the register, at which point its bank account is frozen and any remaining assets pass to the Crown — a genuinely bad outcome for a company that's meant to be holding funds on behalf of the building's leaseholders.
Separately from anything filed at Companies House, an RTM or RMC company also has to maintain its own internal register of who holds what — a share register if the company is limited by shares, or a membership register if it's limited by guarantee (the more common structure for RTM companies). This tracks who the current leaseholder-member is for each unit, and needs to be kept up to date as units change hands, with the company typically issuing a share or membership certificate to each new holder.
In practice this register tends to fall out of date fastest of anything the company is responsible for — a flat gets sold, the paperwork gets handled by the conveyancing solicitors, and updating the company's own internal register slips through the cracks unless someone is specifically responsible for it.
PropLinker's Company Secretary module links a building to its Companies House number and checks it daily, showing the next Confirmation Statement and accounts due dates on the building's dashboard, with automatic email reminders at 60, 30 and 7 days before each one. It also keeps the internal share or membership register — one entry per unit, with a PDF certificate generated automatically whenever a unit changes hands — and gives each leaseholder read-only access to their own certificate from their owner portal.
What it deliberately doesn't do is file anything on your behalf. Confirmation Statements and annual accounts still have to be filed directly with Companies House (or through your accountant) — PropLinker's job is making sure you know the date is coming with enough notice to actually do something about it, not replacing the filing itself.
Do RTM and RMC companies really have to file a Confirmation Statement even if nothing has changed?
Yes. "No changes since last year" is a valid answer, but it still has to be actively confirmed and filed — it isn't assumed by Companies House if you simply do nothing.
Is there a fine for filing the Confirmation Statement late?
Not an automatic banded one, but Companies House can now issue a civil penalty of up to £5,000 under the 2024 ECCTA reforms, and persistent non-filing leads to strike-off. Annual accounts, by contrast, do carry an automatic sliding penalty starting at £150.
Can an RTM or RMC company file dormant accounts?
Often, yes — many qualify because service charge funds are held on trust rather than as company income, but this depends on the specific company's structure and how funds are held. Confirm with an accountant rather than assuming.
What's the difference between a share register and a membership register?
A share register applies to a company limited by shares; a membership register applies to one limited by guarantee, which is the more common structure for RTM companies. Both serve the same purpose — recording who currently holds the interest tied to each unit.
Does PropLinker file the Confirmation Statement or accounts for us?
No. PropLinker tracks the dates, syncs directly with Companies House daily, and sends reminders — but the actual filing is still done by the company (or its accountant) directly with Companies House.
*This article is general information, not legal or accounting advice. RTM and RMC directors should confirm their specific filing obligations with a qualified accountant or company secretary.*
PropLinker handles service charges, GoCardless payments and accounting — built for UK RTM companies.