Registering as an ACSP – confusion and delays!

There seems to be a lot of confusion about registering as an ACSP (Authorised Corporate Service Provider), including why firms need to register, when you need to register and what you can do once you are registered.

In this article we will look at the role of an ACSP, also known as a Companies House authorised agent, the draft timetable for implementation and the pros and cons of performing certain tasks.

To do this, let’s start at the beginning.

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Economic Crime and Corporate Transparency Act 2023 (ECCTA)

The Act brought into law various new powers for Companies House - many of which are now in force – but this had relatively little impact on the average accountancy firm, with perhaps the exception of having to make sure all clients had registered a proper email address and postal address (no more PO Boxes) with the registrar.

However, the imminent implementation of the ID requirements in ECCTA are going to have a much more significant impact on companies and firms.

The core requirement we have considered in this article, is that after a transition period, company documents (e.g. incorporations, accounts and confirmation statements) will only be able to be submitted by the company itself or an Authorised Corporate Service Provider (ACSP). Also, these submissions will only be accepted once the company has identified the directors and PSC’s, either directly with Companies House or via an ACSP.

Do I need to register as an ACSP for company secretarial services?

If you are a firm of accountants wanting to be able to incorporate new companies, file accounts and / or annual confirmation statements on behalf of a company then yes, you will need to register as an ACSP.

If you are already offering these kinds of services, you will be part of the regulated sector for anti-money laundering purposes and can register as an ACSP. You will need to provide your AML registration number, verify the ID of a senior individual and pay a one-off registration fee of £55.

This registration process was supposed to start on 25 February 2025 but was delayed, with no confirmed timetable available as at time of writing.

Do I need to register as an ACSP to provide ID verification services?

If you are a firm of accountants wanting to be able to certify the ID of directors and PSC’s for Companies House purposes then you need to be an ACSP and can register as above, when the process is made available. There is just one registration which will allow you to preform one or both of these services.

ID verification is easy for accountants as we’ve already done it for AML!

No, you really haven’t! At least it is very unlikely, given the different requirements. For Companies House purposes, there are essentially 3 ways to verify the ID (of all directors and PSCs):

1. Directors / PSCs ID themselves directly with Companies House (expected to be available from 25 March 2025)
2. ACSPs verify the ID of Directors / PSCs via electronic software with identification document validation technology (IDVT). Note this is different from a system that takes a client’s ID information and cross checks it to various databases – this must be a system that scans the document itself and confirms it is authentic via the image or the embedded chip.
3. ACSPs verify the ID of Directors / PSCs via paper documents, after the ACSP has undertaken appropriate training. The documents must either be two from list A in the rules (which includes documents such as passports or photocard driving licences), or one from list A and one from list B (which includes documents such as a birth certificate or utility bill). The guidance issued by Companies House makes clear that at least one of the documents must be a photographic one.

Key problems

All 3 of the options above are a problem for most firms; option 1 could lead to frustration and delays from the client, option 2 involves buying new software and option 3 involves mandatory training for the people performing the checks.

The latter must be from any organisation that follows the Home Office best practice guide, including:

• Home Office (HO)
• National Document Fraud Unit (NDFU)
• National Protective Security Authority (NPSA)

Looking at the guidance produced by Companies House (How to meet Companies House identity verification standard) it is clear that the level of checking on paper documents goes well beyond what most firms do when complying with the AML regulations. For example, the guidance refers to checking their address history, checking if they have changed their name and checking if they have regularly interacted with other organisations or people.

Once there is new software and / or new training in place, the firm will need to re-verify all directors and PSC’s by Autumn 2026.

What next for ACSP?

There is a little bit of time to think this through, and ID verification will not become compulsory (on incorporation, for new directors and PSCs and for annual confirmations) until “Autumn 2025”. However, firms would be wise to start to considering their strategic response to this issue now, which may involve urgently training staff, investigated new software and drafting communication for clients.

So while all firms will no doubt register as an ACSP, there are still big questions over who / how ID will be verified and who will pay for the time it takes.