I guessed right. CIPC are now sending out warnings and in them they state that the Beneficial Ownership return must be submitted annually.

The reason that I saw this coming is that they used to insist on a CoR30.2 Financial Accountability Form before you could submit your Annual Return. Then about 18 months ago, the CoR30.2 disappeared and you could submit your Annual Return without it. What they were clearly doing was hacking their own software so that instead of forcing you to submit a CoR30.2, they could use it to force you to submit a Beneficial Ownership Return. That’s exactly what happened, but the problem was that the CoR30.2 was required to be submitted annually, so there was no need to check whether it had already been submitted before allowing you to submit your Annual Return.

So now, because of their ham fisted approach to the problem, they can’t check whether you already submitted your BO return and instead are making you submit a new one every year.