It’s important that Companies House knows who’s filing information on the public register to make sure the information we hold is accurate, transparent, and not being used for fraudulent purposes. However, we do not currently have a full picture of who’s filing this information.
Identity verification is an important part of the Economic Crime and Corporate Transparency Act. Under the act, Companies House will be required to verify the identity of anyone who’s submitting information to the public register, including those acting on behalf of a company.
Why we’re introducing identity verification
Our new powers will make the information we hold more accurate and transparent. It will also allow us to work more effectively with regulators and supervisory bodies through data and intelligence sharing.
Requiring third party agents to register their business and verify their identity will allow us to confidently identify who’s filing on the register and acting on behalf of companies. We'll also be able to quickly identify when an agent may not be acting with a lawful purpose, and we’ll be able to take action. This will help us to effectively protect lawful businesses and the public.
Authorised Corporate Service Providers (ACSPs)
In the future, all third-party providers will need to register their business as an Authorised Corporate Service Provider (ACSP) before they can submit information and carry out identity verification checks on their clients. Over the coming months, we’ll explain when these changes will come into effect.
An ACSP is a business that’s covered by Money Laundering Regulations, such as:
- Professional Service Providers (for example, accountants and solicitors)
- Trust and Company Service Providers (for example, company formation agents)
Standards to become an ACSP
To become an ACSP, agents must be supervised within the UK by one of the relevant Anti-Money Laundering (AML) supervisory bodies, such as:
- HMRC
- Financial Conduct Authority
- The Gambling Commission
There are 25 supervisory bodies in the UK in total. You can find a full list on GOV.UK.
As part of the ACSP registration process, we'll ask for the AML supervisory body membership number for the business, sometimes called an ID number. It’s important to make sure this is accurate.
Agents who operate as a sole trader or are part of a company that’s not registered with Companies House will still need to register as an ACSP, but will be asked for more details. This is so we can cross-reference the information provided with the AML supervisor’s data, as Companies House does not hold any records for non-incorporated companies.
If you’re a software provider, filing information on behalf of a company or third-party provider, you’ll also need to register as an ACSP. You’re now included in the new legislation because you’re responsible for filing information on the register through your software service.
The registrar has new powers to ensure compliance of ACSPs. This includes the ability to suspend or cease an ACSP, for example if the registrar has reason to believe an ACSP is no longer a fit and proper person.
Registering to become an ACSP
If you hold a senior role within the business, such as a director, you'll need to complete a registration process to register your business as an ACSP. You'll be asked to complete identity verification as part of the application. You’ll provide information about the business, which you’ll need to keep up to date once registered as an ACSP. If your business is a sole trader, you will need to provide additional information, for example your name and date of birth.
Once registered, the ACSP will be provided with a new digital account and a unique identity number. This will allow them to file information and complete identity verification checks for their clients and enable Companies House to identify that the information has come from an authorised source.
The person registering the business as an ACSP will be able to add other people who work for the business to the ACSP account once it has been registered and approved. These employees will not be subject to identity verification but will be allowed to access services on behalf of the authorised agent, such as being able to carry out identity checks and file accounts for clients.
Next steps
The new registration service, combined with an intelligence and enforcement process will help us to maintain the accuracy of the information agents provide us. This will help protect the public and disrupt fraud.
If you’re an agent, you do not need to do anything yet. We’ll announce when the registration service will launch in advance to give you plenty of time to prepare, and we’ll publish guidance on GOV.UK to help you with your responsibilities. In the meantime, you can get ready by making sure you understand:
• the standards you need to meet before applying to become an ACSP
• where to find your AML membership number
To find out more about the changes to UK company law, visit our website, sign up for email newsletters and follow us on social media.
56 comments
Comment by Phil Jones posted on
Directors of a company will be required to provide ID but not register as ACSPs... Is that right..?
Comment by Luke C posted on
Hi Phil, thanks for your question.
That’s correct. Only someone acting on behalf of another company needs to register as an ACSP. Directors of a company acting on behalf of their own company do not need to register as an ACSP, but do need to still verify their identity when this becomes a requirement.
Comment by Carmen Stevens posted on
Please can you clarify the comment "if you're a software provider.....you'll also need to register as an ACSP". Software providers do not carry out the filings on behalf of companies, company secretaries and ACSPs use the software platforms to file instead of using web-filing - how will the "new digital account" for ACSP's therefore work with the software platforms?
Comment by Luke C posted on
Hi Carmen, thank you for your question.
Software providers will need to register to become an ACSP if you’re delivering information to Companies House through your software on behalf of your clients, and you are:
- responsible for paying
- engaging directly with Companies House
You will not need to become an ACSP if your clients are using your software but have their own accounts with Companies House.
Companies House will design the processes so that you can provide the relevant information as part of your software submissions. We’ll give plenty of notice about the changes you’ll need to make and will be providing further detail on this in the near future.
Comment by Jeffrey Shaw, solicitor, Nether Edge Law posted on
As a solicitor who occasionally (via a company formation agent) incorporates Flats Management companies for my clients, will it be I or my c.f.a. who needs to register and become an ACSP?
Comment by Luke C posted on
Hi Jeffrey, thanks for your question.
Someone who holds a senior role (such as the director) in the company who files your information will need to register the company as an ACSP. Once they've registered and the account has been approved, they'll be able to add people who work for the company to the ACSP account. They'll be allowed to access services on behalf of the registered company, such as carrying out filings and identity checks for their clients.
Comment by Gill Long posted on
Hello
Please could you advise when this will come into force.
Many thanks
Comment by Luke C posted on
Hi Gill,
Over the coming months we’ll explain more about when these changes will come into effect. We will make sure we give plenty of notice before you need to take any actions.
Comment by JT posted on
When will ID verification come into force and how much notice will be given to comply?
Comment by Luke C posted on
Hi Julie, thanks for your comment.
We'll share more details about the timescales and when these changes will come into effect over the coming months. We will give plenty of notice before you need to take any actions.
Comment by Tony Kazaz posted on
Accountants registered as ACPS`s.
What will their duties, responsibilities and liabilities be.
Is there any time frame within which the requirement is to be mandated.
Comment by Luke C posted on
Hi Tony, thanks for your comment.
We will be publishing full guidance for ACSPs in the near future, including details around timescales and when these changes will come into effect. We will provide plenty of notice before you need to take any actions.
Comment by Gordon posted on
What are the timescales for this change, please? By when will my company's Accountants need to be formally registered in order to continue filing on my company's behalf?
Thanks.
Comment by Luke C posted on
Hi Gordon, thanks for your comment.
We'll share more details about the timescales and when these changes will come into effect over the coming months. We will give plenty of notice before you need to take any actions.
Comment by Yolanda posted on
Hi, we are a Trust & Corporate Service Provider registered in Ireland. Will it be a way for us to register to do third party filings?
Thanks in advance for your reply
Comment by Luke C posted on
Hi Yolanda, thanks for your comment.
To continue filing, you'll need to be AML supervised within the UK in order to become an ACSP, regardless of where your company is based. You can find guidance at http://www.gov.uk/anti-money-laundering-registration
Comment by David posted on
Please clarify , as a small bookkeeper practitioner , who is registered by HMRC "AML" , will they need to make an additional registration for ACSP
Comment by Luke C posted on
Hi David, thanks for your comment.
Anyone who intends to carry out identity checks and file information on behalf of other companies will need to register with Companies House as an ACSP, confirming that they are AML regulated.
Comment by Laszlo posted on
If I am both the director and the owner of my own company, and I am an EU citizen with no passport, only a national ID card, do I still need to complete the identity verification process? If so, when does it become mandatory, and how much time will companies be given to prepare?
Comment by Luke C posted on
Hi Laszlo, thanks for your comment.
Yes, you will need to verify your identity. We will give plenty of notice before you need to take any action, as well as publishing further guidance in advance before you need to do anything.
You can find out more about the accepted photo ID for GOV.UK One Login here: http://www.gov.uk/using-your-gov-uk-one-login/proving-your-identity
ACSPs will be able to consider a range of different documents to verify identities. We'll publish full guidance on the documents they will be able to use for verification in the future.
Comment by Jon E posted on
Do we yet know when these changes will be coming in?
Comment by Luke C posted on
Hi Jon, thanks for your comment.
We'll share more details about the timescales and when these changes will come into effect over the coming months. We will give plenty of notice before you need to take any actions.
Comment by Tony posted on
According to the Collins dictionary, in the "coming months" means:
"A coming event or time is an event or time that will happen soon."
Would you therefore agree that we may expect the changes will come into force this year.
Comment by Luke C posted on
Hi Tony, thanks for your comment.
We'll share more details about timescales when we can. We'll give you plenty of notice before you need to take any action.
Comment by Jasmine P posted on
Will Company Secretaries be required to register as a ACSP?
Comment by Luke C posted on
Hi Jasmine, thanks for your comment.
No. Officers and employees of a company will not need to register as an ACSP to file on behalf of their company. However, they will need to verify their identity when this becomes a requirement.
Comment by Rachel Samways posted on
I am a Part-Qualified Accountant and have been in practice for over 30 years. What will I need to do to continue filing for my clients? I am not part of any professional "Body" but am an agent with HMRC for all my clients. Does this allow me to register as an ACSP?
Comment by Luke C posted on
Hi Rachel, thanks for your comment.
All third-party providers will need to register as an ACSP in order to continue filing on behalf of clients, including those who operate as a sole trader. To become an ACSP, you must be registered with an AML supervisory body in the UK, this includes HMRC. You can find out more information about AML registration here: http://www.gov.uk/guidance/money-laundering-regulations-who-needs-to-register
Comment by Helen posted on
Please can you clarify whether I will be required to register as an ACSP? I work in-house for a large organisation and am responsible for making electronic filings for a number of legal entities. My role is purely administrative (Company Secretarial Asst) and is not a senior position.
Comment by Luke C posted on
Hi Helen, thanks for your question.
Officers and employees of a company, including company secretaries, will not need to register as an ACSP to file for the company they work for. However, if the organisation you work for submits filings on behalf of other companies, then someone who is in a senior role in the business will need to register their company as an ACSP. Once they have done this, they can add you as an employee of that company and you will be able to continue with your filings as normal.
Comment by Kerry posted on
Hi Luke, if I may add a question here please, could you please confirm if group subsidiaries would be classed as third parties in this context? As an company secretariat, we file for our subsidiary entities. Would our company need to register to file on behalf of those companies please? Thanks
Comment by Ellis Davies - Digital Engagement Lead posted on
Hi Kerry, thanks for your comment.
Subsidiaries are separate and distinct legal entities from their parent companies, and their governance is independent. So to file on behalf of another part of a group, they would need to register as an ACSP.
Comment by Lourens posted on
I lead a team working for a charity, which provides professional services to other charities - including preparing and independently examining the accounts of charitable companies. We are exempt from AML registration (confirmed with HMRC and professional accounting bodies / other AML regulators), because as a charity we are not providing these services (to other charities) by way of business.
Am I correct in reading this post to mean that we will now have to register for AML supervision in order to file accounts for our charitable company clients - even though we are exempt under the relevant legislation?
Comment by Luke C posted on
Hi Lourens, thanks for your question.
Charitable companies and Community interest companies (CICs) are within scope of identity verification. If the organisation is filing accounts on behalf of other companies (whether charitable or not) they will need to register to become an ACSP. Anyone who delivers information onto the register for a third party (an agent) will need to become an ACSP.
Comment by Lourens du Plessis posted on
Thank you, Luke, appreciate the reply. I understand we would need to regiser as a ACSP as we would file accounts on behalf of charitable companies. My question is different: by law and under the AML regulations, we are exempt from AML regulation, as we are a charity ourselves, delivering these services "not by way of business". By making AML regulation a mandatory condition of being able to register as an ACSP, Companies House is unilaterally forcing us to be subject to AML regulation because of a very small part of our overall activities.
This requirement is very challenging for the charity sector more widely. Many trustees rely on volunteer accountants to assist them. They won't be able to register in this way, and there is a significant capacity challenge in the accounting profession, so they cannot pick up the baton (which would come at a high cost for charities).
So can I confirm: CH is unilaterally going to force our entire organisation to register for AML regulation, or force us to have to close down an entire service area?
Comment by Ellis Davies - Digital Engagement Lead posted on
Hi Lourens, thanks for your comment.
S1067a of the Companies Act 2006 confirms who may file on behalf of a company - this includes an officer or employee of the company who’s verified or an Authorised Corporate Service Provider (ACSP).
The Economic Crime and Corporate Transparency Act sets out one of the criteria that must be satisfied to register as an ACSP. That is, the 3rd party must be supervised for MLR purposes. As this is a requirement in the primary legislation, there are no exceptions.
Volunteer accountants should be able to register as an ACSP and continue to file on behalf of the charitable companies. It’s typical that accountants will be supervised for MLR purposes.
You may wish to seek legal advice to determine if you can choose to register for MLR supervision, should you wish to become an ACSP.
Comment by Leyla posted on
Will there be a fee to register as an ACSP?
Comment by Luke C posted on
Hi Leyla, thanks for your question.
There will be a fee to register as an ACSP but the amount is still to be determined. We'll share more details about this when we can.
Comment by KLynne posted on
If a firm of accountants registers as an ACSP to file on behalf of its clients, do all individuals of the firm that normally carry out filings need to be verified or notified to Companies House, or once registered can anyone within the firm file using a central code?
Comment by Luke C posted on
Hi Kathryn,
Someone who holds a senior role in the accountancy firm, such as the director, will need to register the business as an ACSP. They'll be asked to complete identity verification as part of this registration. Once the registration is submitted and approved, the ACSP will be provided with a new digital account and a unique identity number. The person who registered the business as an ACSP will then be able to add other employees who work for the business to the online ACSP account.
These employees will not need to undergo identity verification, but will need to be added to the ACSP account before they're able to continue carrying out services on behalf of the ACSP, such as filing accounts for their clients.
Comment by Josh G posted on
Hi, will a UK establishment of an overseas entity need to engage with an ACSP to keep their records up to date the same as a UK company? (if an officer is not doing this themselves)
Comment by Ellis Davies - Digital Engagement Lead posted on
Hi Josh, thank you for your comment. UK establishments of overseas companies will also be subject to identity verification and will need to verify directly with Companies House.
Comment by GWhite posted on
Hello. Do persons filing documents need to be direct employees of an ACSP or can they be an employee of a service company to the ACSP?
Comment by Ellis Davies - Digital Engagement Lead posted on
Hi, thank you for your comment. Section 1067a of the Companies Act 2006 contains a useful table detailing who can file on behalf of an ACSP.
Companies are always advised to seek independent legal advice around the specific particulars of their organisation and its obligations.
Comment by gavin doyle posted on
Is there a tender process being run to provide or develop the identity verification solution?
Comment by Ellis Davies - Digital Engagement Lead posted on
Hi Gavin, thanks for your comment. We're joining GOV.UK One Login. Read more about our move to GOV.UK One Login.
Comment by Bryony posted on
I work for a TCSP, we are AML supervised and carry out CDD including identification verification. We do not update Companies House on behalf of any of our customers however we do use the website as a tool to assist with our CDD. Do we need to register as a ACSP? Thank you.
Comment by Luke C posted on
Hi Bryony, thanks for your question.
Anyone who intends to carry out identity checks and file information on behalf of other companies will need to register with Companies House as an ACSP.
Comment by Bryony posted on
Hi Luke,
Thanks for your response. Could you clarify - if we do both (ID verification and update CH on behalf) we need to register as an ACSP? Or if we either of those two things, we still need to? We only do one of those two things so just need to understand if it only a requirement if we do both, or if we still need to just doing one.
Thank you.
Comment by Ellis Davies - Digital Engagement Lead posted on
Hi Bryony, thanks for your comment. An individual or firm must register as an ACSP if they wish to undertake identity verification checks, or, if they wish to deliver documents to the registrar on behalf of a company. They do not need to be doing both.
Comment by SG posted on
Very useful information. Thank you.
If a person has had their identity verified under the Register of Overseas Entities, will they need to verify it again under the new ECCTA 2023 rules?
Thanks
Comment by Ellis Davies - Digital Engagement Lead posted on
Hi, thanks for your comment. Yes, all directors, people with significant control (PSCs) and individuals filing with Companies House will be required to verify their identity under the Economic Crime and Corporate Transparency Act 2023.
Comment by MDF posted on
I use a virtual address service as I have no physical head office location, and do not wish to expose my home address. What should I expect the service provider who is maintaining our corporate address to request from me in order that both they and I continue to conform to the new legislation?
Is there any circumstance when I would be expected to give them authority to make filings (and thus have an authentication code), or would I be expected to provide more conventional forms of proof of identity?
Comment by Ellis Davies - Digital Engagement Lead posted on
Hi, thanks for your comment.
All directors and PSCs of your company will be required, under the new legislation, to verify their identity. Once your identity has been verified, you have the option to file for your own company. You can also choose to contract these filings out to an agent to file on your behalf, but they must be registered as an ACSP.
If you decide to use an ACSP, your service provider will be expected to provide us with the necessary verification confirmation as laid out in the legislation and regulations. We're continually engaging with the industry to make sure they're ready for these changes.
ACSPs are advised to seek legal advice if they're unsure of their specific obligations once registered as an ACSP.
Comment by Elaine posted on
Hi,
We are an ABS regulated by SRA but our consultants need to file charges with Companies House, do we as an ABS need to register as an ACSP or can our consultants register as an ACSP?
Thanks
Comment by Ellis Davies - Digital Engagement Lead posted on
Hi Elaine, thanks for your comment. S1067A of the Companies Act 2006 contains a useful table detailing who can file on behalf of a company and/or an ACSP. Companies are advised to seek independent legal advice around the specific particulars of their organisation and its obligations.