Have there been any changes to the filing obligations of limited partnerships due to the coronavirus (COVID-19) pandemic?

Due to the impact of the coronavirus (COVID-19), legislation has been adopted to temporarily extend the filing deadlines in respect of a number of different entities. The Companies etc (Filing Requirements) (Temporary Modifications) Regulations 2020, SI 2020/645 (the Regulations), which came into force on 27 June 2020 and which were introduced in response to the COVID-19 pandemic, have among other matters temporarily extended the deadline for notifying changes in a limited partnership (LP) from seven to 42 days. The Regulations were issued pursuant to the Corporate Insolvency and Governance Act 2020 (CIGA 2020), which came into force on 26 June 2020. As noted above, the modifications introduced by the Regulations are temporary and extend relevant filing deadlines falling between the 27 June 2020 and the end of the day on 5 April 2021 (although the Regulations provide an ability to extend that period by virtue of a savings provision in CIGA 2020, s 39(9)).

The above means that during the period covered by the Regulations (the Period), if during the continuance of an LP which is not a private fund limited partnership (PFLP), ie a non-PFLP, any change is made or occurs in:

• the firm name

• the general nature of the business

• the principal place of business

• the partners or the name of any partner

• the term or character of the partnership

• the sum contributed by any limited partner, or

• the liability of any partner by reason of that person becoming a limited instead of general partner or vice versa

the general partners must notify Companies House of the change within 42 days using form LP6.

In addition, if during the Period where an LP is a PFLP, any change is made or occurs in:

• the firm name

• the principal place of business

• the partners or the name of any partner, or

• the liability of any partner by reason of that person becoming a limited instead of general partner or vice versa

the general partners must notify Companies House of the change within 42 days using form LP6.

Finally, if during the Period a PFLP which was previously registered as an LP prior to 6 April 2017, ie it was previously a non-PFLP prior to the entry into force of the changes to the Limited Partnerships Act 1907 (LPA 1907) implemented by the Legislative Reform (Private Fund Limited Partnerships) Order 2017, SI 2017/514 (LRO), the general partners must additionally notify Companies House within 42 days using form LP6, if any withdrawal by a limited partner of its partner's contribution to the PFLP is made which has the effect that the partner's contribution amount is less than it was on the date on which the LP was designated as a PFLP.