The landscape of UK corporate governance is changing. Driven by evolving regulations designed to enhance transparency and combat financial crime, the introduction of the ECCTA brings with it substantial alterations, placing accountants and third-party service providers at the forefront of a significant transformation.
The Economic Crime and Corporate Transparency Act
The ECCTA aims to strengthen the overall business landscape in the UK. It enhances the function of Companies House by empowering us with increased enforcement capabilities which will allow us to pursue more effective investigations and enforce greater legal sanctions against those committing economic crime.
The act focuses on improving the visibility of corporate ownership by mandating the disclosure of beneficial ownership information and reducing opportunities for criminal activity to go undetected.
A key element of the act centres around a new requirement for identities to be verified before information can be filed on the Companies House register. We believe implementing this regulation will help us to take a significant step forward in our overall efforts to promote a more accountable business environment.
The Authorised Corporate Service Provider (ACSP) requirement
The changes brought about by the ECCTA will be introduced incrementally across the next few years. Once fully implemented, there will be a new requirement for third-party providers to register as Authorised Corporate Service Providers (ACSP) in order to file information or verify the identities of their clients.
Applicants will have to be supervised by a UK Anti-Money Laundering (AML) supervisory body. There are currently 25 AML supervisory bodies in the UK, including CAEW and ACCA. A full list can be found via the GOV.UK website.
When the registration service goes live, applicants must reference their supervisory body membership number. There will also be a requirement for non-incorporated businesses or sole traders to provide additional information which will be cross-referenced with AML data.
After an ACSP registration has been completed, ACSPs will be provided with a digital account and a unique identity number. This will then allow them to carry out identity verification checks for their clients and also to upload client identity information to the register.
Once client identity credentials have been received by the Registrar, a Companies House Personal Code will be sent to the identity verified individual. This code will be requested during the submission process. From Autumn 2025, additional information relating to the incorporation or appointment of individuals will also be required.
Key steps to prepare for the spring 2025 registration
- Identity Verification Processes: Update and review your IDV processes to ensure they align with these new requirements.
- Familiarisation with latest procedures: Ensure you understand the application process to become an ACSP through Companies House’s systems, to make sure this transition is as smooth as possible.
- Anti-Money-Laundering Compliance: Verify your status as AML regulated, as this is an essential prerequisite to become an ACSP, and make sure you know where to find your membership number as this will be required for the ACSP registration.
Impact and risk
From February 2025, third-party providers who will be carrying out identity checks on behalf of clients for Companies House will need to register as an Authorised Corporate Service Provider (ACSP). From Spring 2026, third party providers will also need to register their business as an ACSP to file any information on behalf of other companies.
Companies House encourages those in the accountancy sector to engage in this process from an early stage. We believe this will foster best practice, allowing sufficient time to adapt ahead of the ACSP requirement becoming a legal obligation.
Our approach in the future will be to work alongside ACSPs to aid them with compliance, raising any potential issues with compliance standards and assessing whether information filed is accurate. Should an ACSP be found to be non-compliant, the Registrar has the power to suspend an ACSPs account while any misconduct is investigated. The Registrar also has the power to cease the ACSP completely if they are deemed unfit to carry out ACSP functions. Public notices will be published when an ACSP has been suspended or ceased.
Action plan
To ease the transition, accountants should:
- Become Anti-Money-Laundering compliant
- Keep up to date with the ACSP registration process via Companies House
- Implement vigorous identity verification processes in ongoing practice
Future-proof your practice
We implore accountants to take up these proactive steps voluntarily from February 2025. Preparing for these changes will ensure that all accountants can become leaders in compliance and corporate governance.
Detailed resources and guidance on meeting the new standards will be available and regularly updated via the Companies House website.