New identity verification requirements for company directors and individuals with significant control (PSCs) reforms by Companies House are expected to impact approximately 7.4m existing officers listed on the register who will need to undergo verification.
Under the Economic Crime and Corporate Transparency Act 2023 (ECCTA), Companies House must verify the identity of anyone submitting information to the public register, including those acting on behalf of a company. The enhanced powers granted to Companies House are intended to improve the accuracy and transparency of the information it holds.
Requiring third-party agents to register their businesses and verify their identities will allow Companies House to confidently identify who is filing information on the register and acting on behalf of companies. This capability will enable quicker identification of agents who may not be acting with a lawful purpose, allowing Companies House to take appropriate action.
Companies House reform timelines
The Companies House reforms under the Economic Crime and Corporate Transparency Act are set to follow a clear timeline:
- 18 March 2025: third-party providers able to register as an Authorised Corporate Service Provider.
- 8 April 2025: the new identity verification requirements come into effect on a voluntary basis.
- Autumn 2025: mandatory identity verification for all company directors and People with Significant Control (PSCs) on incorporation and appointment.
- 12-month transition period: existing directors and PSCs will have a year to comply with the new requirements, and so will be required to have completed identity verification by autumn 2026.
Authorised Corporate Service Providers
In the future, all third-party providers will need to register as an Authorised Corporate Service Provider (ACSP) before they can submit information and conduct identity verification checks on their clients.
An ACSP is a business subject to Money Laundering Regulations, such as:
- Professional Service Providers (eg, accountants and solicitors); and
- Trust and Company Service Providers (eg, company formation agents).
To become an ACSP, agents must be supervised within the UK by one of the relevant anti-money laundering (AML) supervisory bodies, such as ICAEW.
How to register as an ACSP
Individuals in senior roles within a business, such as directors, will need to complete a registration process to establish their business as an ACSP. This process will include identity verification as part of the application. Applicants will also need to provide business information, which must be kept up to date once registered as an ACSP. Sole traders must supply additional personal information, such as their name and date of birth.
Upon successful registration, the ACSP will receive a new digital account and a unique identity number. This account will allow them to file information and conduct identity verification checks for their clients. It will also enable Companies House to confirm that the information comes from an authorised source.
The person registering the ACSP will be able to add other staff members to the ACSP account once it is approved. These additional employees will not need to complete identity verification but will be permitted to access services on behalf of the authorised agent, including performing identity checks and filing accounts for clients.
Key requirements for ACSP registration
According to the latest Companies House guidance, to register as an ACSP, businesses must meet specific eligibility criteria, including:
- sole traders can register as authorised agents;
- applicants for business registrations must hold a senior role, such as a director, general partner, or equivalent; and
- businesses must be registered with a UK AML supervisory body.
Applicants must verify their identity before using the Companies House online service to register as an ACSP. If identity verification is not completed prior to application, the system will prompt applicants to do so.
Legal responsibilities of ACSPs
Once registered, authorised agents must:
- maintain continuous registration with a UK AML supervisory body;
- notify Companies House of any changes to their details; and
- keep records and provide additional information on filings with Companies House upon request.
Guidance for identity verification
When an ACSP verifies someone's identity, they must:
- collect the person's full name, date of birth, and address;
- review documents that verify the person's identity;
- authenticate documentation using Identification Document Validation Technology (IDVT) or manually by a trained professional; and
- ensure the identity belongs to the person claiming it by cross-referencing documents and biometric data.
Delayed timeline
Originally, registration as an ACSP was expected to begin on 25 February 2025 with the opening of the online registration system. However, this was delayed until 18 March 2025 and the introduction of voluntary ID verification was pushed back to 8 April (it had been due on 25 March).
The temporary delay in ACSP registration does not impact the broader Companies House reform timelines. The introduction of identity verification and related reforms will proceed as planned, although the delay in the online portal availability may reduce the time those firms intending to offer ACSP services have between registering and beginning identity verification for clients.
Correction: date changes
On 12 March government announced changes to the timings for aspects of these rule changes. That introduction of voluntary enrolment as an ACSP will be on 18 March (from 25 February). The 25 March introduction of voluntary director ID is now 8 April.