The Economic Crime and Corporate Transparency Act 2023 (ECCTA) saw a recent update to its identity verification requirements; with Companies House announcing the ID verification requirements for directors and PSCs. The requirement came into effect on 18 November 2025. This date marks the start of the regime for new incorporations and appointments, with a transition period extending to autumn 2026.
Identity verification will be conducted directly through Companies House or an Authorised Corporate Service Provider (ACSP), which is a regulated third party able to carry out verification and file a statement confirming the checks.
Professional firms like accountants, company formation agents, and law firms are likely to be among the primary third parties registering as ACSPs, since these firms already function within AML supervision systems.
In addition, as an ACSP, accounting firms are responsible for conducting identity verification processes of their clients and filing accurate information documents and submitting them to their respective Companies House. The scope of their responsibilities will be in two ways: towards the regulatory authorities and towards their clients.
For each individual they verify, ACSPs will submit the required verification statement or notification to Companies House, confirming that the identity checks meet the prescribed standard. The process of verification should be diligently conducted by an accounting firm in a transparent manner that does not cause undue disruption.
The following blog explains the roles of accounting firms and other ACSPs, their responsibilities, actions related to the November 18th ECCTA 2023 amendment, and how to adapt to upcoming changes in 2026.
What are the responsibilities of ACSP accounting firms?
1. Performing Identity Verification
ACSP accounting firms should verify the identity of anyone who plays a significant role in the client’s company, such as a director, PSC, LLP member, or relevant shareholder. It has to make sure that official identity documents are collected, information is matched against approved verification databases, and that each person has been validated through Companies House-approved digital identity processes.
ACSPs should ensure that verification is performed before any filing in relation to that client is submitted. They also have to put in place formal mechanisms to address failed verifications, discrepancies, and potential fraud in identities. The identity verification process would be approached by ACSPs in the following manner:
- Collect information and documents
ACSPs must meet the Companies House identity verification standard and align with their AML obligations; the specific combinations of documents and checks should follow Companies House and supervisory body guidance. Obtain documentation identifying the individual to a reasonable standard for anti-money laundering purposes, as directed in the Companies House guidance. This may include providing two forms of identification from primary sources (such as a passport or photocard driving licence), or one primary document together with a secondary document, such as a recent utility bill or a birth certificate. At least one should be photographic.
- Perform verification
Electronic verification would use software with IDVT that can scan the document and verify authenticity, while manual verification requires in-person inspection to verify that the photo on an ID matches the individual presenting it. The verifiers are also trained to validate forged documents. To perform verifications remotely, other means that have been devised include capturing a live photo next to the ID to validate that the ID was taken by a real person.
2. Maintain Detailed Records and Compliance Documentation
Records from accounting firms acting as ACSPs should be maintained in respect of all identity checks, supporting documents, due diligence assessments, and verification results. These records should be kept secure and retained for a minimum period of seven years. These include logs of the date, method, verification officer, and evidence used in each identity check.
Additional requirements include ACSPs maintaining internal records of their dealings with Companies House, with filings submitted, correspondence, audit trails, and assessments of compliance. Proper record-keeping ensures transparency and, where necessary, enables regulators or law enforcement to review processes.
3. Filing Documents on Behalf of Clients
Registered ACSPs have the right to file at Companies House on behalf of their clients, including incorporation documents, appointment of directors, confirmation statements, PSC updates, change of registered office, and other corporate-related filings under ECCTA 2023.
Accounting firms should ensure all documents filed are accurate and complete, and that filings are in compliance with all legal requirements. Firms must verify that individuals subject to a filing have completed identity verification before the filing process. The firm is then legally responsible for the filing being correct, meaning any wrong or incorrect filings may be marked as penalties, regulatory action, or even legal consequences.
4. Providing Information and Cooperating with Authorities
As regulated entities, ACSPs must respond promptly to requests for information from Companies House, law enforcement agencies, or supervisory bodies. This includes supplying verification records, AML risk assessments, or relevant internal documents when requested. ACSPs must fully cooperate during investigations, audits, or compliance inspections. They are also required to maintain open lines of communication with Companies House and promptly disclose any issues related to filings, false information, or client non-compliance.
5. Maintaining AML Supervision and Reporting Suspicious Activity
ACSP registered firms are supervised by an approved UK Anti-Money Laundering (AML) supervisory body such as HMRC, ICAEW, ACCA, or the FCA. They must ensure their AML policies and procedures meet regulatory standards, including client due diligence, risk assessments, and ongoing monitoring. ACSPs are legally required to report suspicious activity to the National Crime Agency (NCA) through Suspicious Activity Reports (SARs) whenever they identify unusual behaviour, discrepancies, or suspected criminal activity. Not reporting suspicious activities may be considered a breach of AML compliance.
6. Implementing Internal Controls, Training, and Monitoring
ACSP registered firms must establish strong internal controls to manage identity verification, AML compliance, and secure filing practices. This includes formal written procedures, regular internal audits, a designated compliance officer, and secure data-handling systems to protect client information. Staff members involved in filing or verification must receive continuous training on ECCTA 2023 requirements, AML obligations, risk identification, and digital verification processes. Firms must also monitor compliance performance and update their internal procedures to reflect regulatory changes, emerging risks, or Companies House guidance.
7. Keeping ACSP Registration Details Up to Date
To maintain ACSP status, accounting firms must promptly update Companies House whenever their own business details change. This includes changes of office address, AML supervisory body, senior management, verification officers, or ownership structure. Firms must also ensure their ACSP registration remains valid, compliant, and free from regulatory breaches that could lead to removal from the ACSP register. Keeping details up to date ensures the firm retains its authority to act on behalf of clients.
Conclusion
As 2026 draws near, the UK government has laid out significant changes to ECCTA 2023 that will impact various sectors. By spring of that year, individuals and organisations will be required to use identification for all document submissions, marking a significant shift in administrative procedures. Furthermore, accounting firms that outsource filing services will need to register as ACSP to comply with new regulatory standards. These developments suggest that accounting practices, along with other affected entities, should proactively prepare for the oncoming changes to ensure smooth transitions and continued compliance.
