From 18 November 2025, Companies House will make identity verification a compulsory part of incorporation and new appointments of directors and Persons of Significant Control (PSCs). Directors and PSCs can choose to verify themselves directly with Companies house, or they can use an Authorised Corporate Service Provider (ACSP) to provide the verification service on their behalf.

And from spring 2026, third-party providers will need to be registered as an ACSP to make any filings on behalf of other companies.

The introduction of this mandatory identity verification for directors and PSCs and the spring 2026 requirement to be registered as an ACSP to make filings on behalf of clients will, for the first time, require firms to be officially authorised to perform identity verification at Companies House or to make filings for their clients. This marks a shift from trust-based filing to a system rooted in verified accountability, transforming how accountancy firms engage with corporate transparency and client onboarding.

Now is a crucial time for firms to plan ahead, prepare for the changes and think carefully about whether becoming an ACSP is right for them. Deciding whether to register as an ACSP requires firms to balance client needs, operational capacity and regulatory burden.

Sandy Price, ICAEW’s Anti-Money Laundering Manager, who explained the ins and outs of compliance on a recent ICAEW webinar for small practices, advises against rushing in: “Observe, prepare and only register when your firm is confident it can meet the verification obligations consistently and correctly.”

ICAEW’s technical support and guidance are available to help firms navigate this change. Here are five key steps to support you through the transition.

1) ACSP registration: dates and strategic decisions

ACSP registration officially opened on 18 March 2025 and if you are planning to provide a verification service for clients, then you should think about registering now.

If your firm does not plan to provide a verification service, then no action is needed for now. But if you are planning to file papers, including accounts, at Companies House on behalf of your clients, then you will need to be registered as an ACSP by spring 2026.

“If you are not planning to verify then you have breathing space to watch how the process evolves and decide if you want to offer verification services yourself or let clients handle it independently,” Price says.

2) Providing verification services: the risks

Registering as an ACSP now allows your firm to verify the identities of directors and PSCs for Companies House. But it is a tightly regulated role with fixed procedures, unlike the risk-based approach of AML compliance.

Mistakes in the verification process could result in your ACSP status being revoked, barring your firm from making future filings. Clients would then need to start over elsewhere, potentially denting trust and damaging your reputation.

For that reason, many smaller firms are choosing to delay registration or partner with digital verification providers instead. While becoming an ACSP may appear to offer added value, it also introduces significant compliance risk and operational pressure.

3) Manual identity checks vs digital ID verification

Firms offering verification services must be supervised for anti-money laundering (AML) by a UK body, such as ICAEW, and follow one of two processes:

• Manual verification requires collecting at least two valid forms of ID and ensuring the verifier is trained to Home Office standards. This training is separate from AML training and must be delivered by a qualified provider. The steps must be followed exactly. No risk-based variation is allowed.
• Digital ID verification is the alternative. While potentially more efficient, it involves investment in software and internal processes.

It is important to understand that the process for identity verification required by Companies House is not the same as verifying a client under the money laundering regulations. Companies House requirements for verification is the same for all clients, whereas the money laundering regulations allow a risk based approach.

4) Applying to become an ACSP: common pitfalls

Applying to become an ACSP requires accuracy and attention to detail. You must submit your firm’s name exactly as listed with ICAEW and Companies House. You must use the correct AML supervision number. This is your firm’s number, not your personal ICAEW membership number and it is on your annual return (C00… or A00…). A one-off £55 fee applies.

Common application errors, for example using a trading name instead of the legal firm name or selecting ‘Sole Trader’ rather than ‘Unincorporated Entity’ for sole practitioners, can lead to delays or rejections.

Companies House, not ICAEW, regulates ACSPs. Although ICAEW can support and guide your firm through the process, it cannot approve your status. Before applying, ensure your AML supervision is current and correctly recorded. ICAEW membership alone is not enough.

5) Decision-making

ACSP registration marks a shift in how firms interact with Companies House and adds another layer of regulatory responsibility. Whether you decide to register or not, now is the time to review your processes, educate your team and plan your next steps.

As Price says: “Watch how it unfolds and take the right approach for your firm when you’re ready.”

Other key AML legislative changes

AML expectations are tightening. The July 2025 National Risk Assessment reaffirmed accountancy as a high-risk sector for money laundering. Of note, the risk of terrorist financing among Trust and Company Service Providers has increased from low to medium.

Regulators are also focusing on cryptoassets, cybercrime and increasingly complex ownership structures.

There are imminent changes to the Money Laundering Regulations. In the future, enhanced due diligence will only be required for jurisdictions on the Financial Action Task Force ‘call for action’ list. This narrows its use, but increases its importance where applicable. The sale of off-the-shelf companies will be in scope of the Money Laundering regulations. There are subtle changes in language too, where firms must be alert to ‘unusually complex transactions’, rather than ‘complex transactions’. Where the Regulations currently cite values in terms of euros, this will in future be quoted in sterling.

Staying informed and supported

ICAEW provides extensive support to help firms stay compliant. Resources include the AMLBites video series and ICAEW’s supervisory team’s AML resources, which includes checklists and templates as well as access to our technical bulletins and confidential helpline.

Firms should remain alert to scam communications. ICAEW has confirmed that HMRC does not email firms asking about their AML supervisory details. Any such message may be a phishing attempt and should be reported before engaging.

For firms without dedicated compliance staff, the Money Laundering Reporting Officer (MLRO) role becomes even more important. ICAEW’s MLRO guidebook provides a succinct summary of your regulatory requirements.

Sandy Price recently spoke in an ICAEW webinar, AML for the small practice, where she shared insight from ICAEW's Quality Assurance team on staying compliant. Access the webinar on demand.

For more information, book this upcoming ICAEW webinar on Becoming ACSP-ready: practical steps for accountancy practices. This virtual webinar is free for members, costs £15 + VAT for non-members and will take place on 8 December at 1pm.