ID verification
As we reported in our October Compliance Update (here), the Economic Crime and Corporate Transparency Act 2023 (ECCTA) gave new powers to Companies House with the aim of making them more of a gatekeeper against economic crime than a passive repository of company data. Since 18/11/25, directors and Persons with Significant Control (PSCs) have been required to verify their identity with Companies House before they can establish companies or file documents (in relation to new and existing companies).
Why?
The aim is to make Companies House a more reliable and accurate source of information, providing greater confidence that companies have legitimate directors and PSCs behind them, by reducing the use of fictitious directors etc. Sadly, as has been reported by Graham Barrow of The Dark Money Files on LinkedIn in recent months, whilst a step in the right direction, this doesn’t prevent companies using proxy directors/ PSCs (real people whose ID can be verified) to hide a company’s true ownership/ control, or indeed using incorrect addresses (as there is no obligation for addresses to be verified as standard at present).
Why you need to do
Despite the potential flaws of the new system, if you are a director or a PSC of a company (including your own law firm if relevant) (or have clients who are) and you haven’t already done so, we urge you to verify your identity with Companies House immediately to avoid filing delays or criminal liability (acting as a director without Companies House ID verification is now a criminal offence). Verification can either be carried out using the gov.uk One Login or by using an Authorised Corporate Service Provider (ACSP). The good news is that ID verification is one-time only, regardless of how many companies or roles you hold. You will be provided with a personal code for all future Companies House interactions.
Is this the same as ID verification under the Money Laundering Regulations (MLRs)?
No! This ECCTA requirement is separate from the AML regime. The LSAG guidance currently says firms cannot rely solely on Companies House data for client due diligence so, while the Companies House verification process will establish that there is a genuine person of that name, and can be taken into account as part of your obligations under the MLRs, it will not:
- confirm that the person you are dealing with is the verified individual, or is the real director/ PSC of your company client.
- provide access to ID documents provided to Companies House
- satisfy PEPs (or Sanctions) screening obligations.
So, while helpful, it will not replace your ID&V or risk assessment obligations under the MLRs.
ACSP regime
Since going to press the Government has confirmed in its Policy Paper dated 19/1/26 that the date from which those filing documents at Companies House must be registered ACSPs will now not be until November 2026.
From spring/ summer 2026 (the exact date is not yet known) only Authorised Corporate Service Providers (ACSPs) will be able to file information at Companies House. Yes, you heard correctly! If you currently file documents on behalf of your own firm or for clients, you will no longer be able to do so unless you have registered as an ACSP first.
Separately, (from now) if you wish to verify clients’ identities at Companies House on their behalf, you must also be registered as an ACSP.
ACSP criteria
- The applicant must be a director, partner or sole trader (and will need to have their ID verified as referred to above)
- The applicant must be registered with a supervisory body under the MLRs (e.g. SRA…for the time-being!) throughout their ACSP registration, and be able to provide evidence of registration (e.g. SRA firm ID)
Whether to become an ACSP – what to consider:
- Insurance: Check your PII covers ACSP work
- Scope: Will you only file documents or also verify ID? For existing clients only, or new/ overseas clients too?
- Verification method: Will you use a third-party software solution or will you do it manually? Be aware that Companies House standards are stricter than those under the MLRs, with no risk-based approach. (And records must be kept for 7 years rather than 5 years under the MLRs, and may be requested by Companies House at any time). See the government guidance here for full details as to how to meet the Companies House ID verification standard.
- Training: How will you ensure staff are properly trained to comply with the requirements (particularly if you opt for manual verification of ID)? Be aware that ACSPs will be required to submit a statement to the Registrar to confirm that their identity checks meet the required standard and that you are satisfied that the person is who they claim to be. False/ inaccurate/ misleading statements about someone’s identity can lead to offences.
- Resources: Do you have capacity to manage this new work stream?
- Risk assessment: Consider AML, data protection and business impact (will you lose clients to other ACSPs if you don’t register as an ACSP?)
- For further details about becoming an ACSP, see the government guidance here.