- When SIC codes are reported
- Common property SPV codes
- Holding company and financing codes
- Project and asset SPVs
- Why lenders care
- Why banks and insurers care
- SIC codes and tax
- SIC codes and regulation
- How to choose a code
- Changing a SIC code
- Dormant and pre-trading SPVs
- Multiple activities
- Example
- Common mistakes
- SPV SIC review checklist
- Frequently asked questions
Updated for 2026/27. Standard Industrial Classification (SIC) codes describe a company’s business activities on the Companies House register. An SPV can list up to four codes. They do not create legal powers or tax treatment, but inaccurate codes can delay banking, lending, insurance, due diligence and regulatory reviews.
When SIC codes are reported
Codes are supplied at incorporation and confirmed or updated through the annual confirmation statement. If the SPV changes from holding property to development, financing or management, update the codes promptly rather than waiting for an investor or lender to identify the mismatch.
Common property SPV codes
- 68100: Buying and selling of own real estate
- 68209: Other letting and operating of own or leased real estate
- 68320: Management of real estate on a fee or contract basis
- 41100: Development of building projects
Use 68209 for ordinary holding and letting where it accurately describes activity; 68100 for buying and selling the company’s own property; 41100 for development. A company doing several genuine activities can select multiple codes.
Holding company and financing codes
Depending on the real purpose, codes can include activities of holding companies, financial intermediation, fund management or head offices. Financial codes can trigger enhanced bank, FCA and anti-money-laundering questions, so do not choose them merely because shareholder loans exist.
Project and asset SPVs
A renewable-energy, film, infrastructure, intellectual-property or securitisation SPV should select the code closest to its substantive activity. The entity may own an asset but earn revenue through energy generation, licensing, leasing or financing. Focus on what it actually does, not the generic phrase “special purpose vehicle”.
Why lenders care
Property lenders often filter applications by accepted SIC codes and expect a clean SPV with limited activity. A code outside policy does not necessarily make the activity illegal, but it can move the application to manual review or make a product unavailable. Confirm criteria before incorporation rather than selecting an inaccurate code to fit a form.
Why banks and insurers care
Providers use codes as an initial risk indicator for expected customers, countries, transaction volume and regulated activity. If account behaviour conflicts with the public code, enhanced checks or account restrictions can follow. Explain genuine changes and update Companies House records.
SIC codes and tax
A code does not determine whether profits are trading, property or investment income, whether VAT exemption applies, or whether Corporation Tax relief is available. HMRC considers contracts, transactions and facts. For example, choosing 41100 does not turn a passive rental portfolio into a property-development trade.
SIC codes and regulation
A code does not grant FCA permission, planning consent, professional authorisation or a VAT option to tax. Conversely, using a non-financial code does not remove regulatory duties where the SPV carries on a regulated activity. Complete a separate regulatory analysis.
How to choose a code
- Describe current and planned revenue-generating activities.
- Search the official condensed SIC list using ordinary terms.
- Select the closest substantive code, not a vague prestigious description.
- Use additional codes only for real material activities.
- Check lender, bank and insurer requirements.
- Align the business plan, accounts, website and contracts.
- Review annually and after a purpose change.
Changing a SIC code
Update it on the next confirmation statement or submit an early confirmation statement if a current public record is commercially important. Filing a new code does not amend the company’s articles, contracts, planning permissions or tax registrations. Those changes require separate action.
Dormant and pre-trading SPVs
A newly incorporated SPV can select the intended activity before transactions begin. Dormant status is an accounting and Corporation Tax concept based on activity, not a SIC code. Once it starts acquiring assets, earning interest or paying significant costs, review whether it remains dormant.
Multiple activities
Companies House permits up to four codes. Select those representing the main activities, but avoid a list of every possible future venture. A lender seeking a bankruptcy-remote or single-purpose entity may require tighter articles and covenants even though Companies House permits several codes.
Example
A company is formed to buy and hold residential property for rent. It selects 68209. Two years later it begins acquiring land and building homes for sale. The directors add 41100 and 68100, update lender and insurer information, and separately review whether the activity is a property-development trade for accounting and tax.
Common mistakes
- Using 99999 when a specific active code exists
- Choosing a lender-preferred code that does not match reality
- Assuming a code creates tax relief or regulatory permission
- Failing to update after the project changes
- Confusing property management for third parties with holding own property
- Listing unrelated activities that undermine SPV restrictions
SPV SIC review checklist
- Current activity matches public code
- Codes align with articles and shareholder agreement
- Lender and insurer have accurate information
- Tax and accounting classification separately documented
- Regulatory permissions separately checked
- Confirmation statement filed and receipt retained
Use the official Companies House SIC list and confirmation statement service. Our SPV registration checklist covers the other incorporation details.
Frequently asked questions
Is there an SPV SIC code?
No single code covers every SPV. Choose the code for the underlying activity.
Can I use more than one code?
Yes, up to four, where each represents a genuine activity.
Will the wrong code invalidate the company?
Not ordinarily, but it can cause compliance, due-diligence and commercial problems and should be corrected.
This guide is general information. Confirm codes against the current official condensed list.