Companies House Identity Verification and ACSP

The Companies House reforms have moved faster than many practices anticipated. Identity verification is not an upcoming deadline — it is already the law for new incorporations and appointments, and the requirement to register as an Authorised Corporate Service Provider (ACSP) for third-party filing agents is approaching rapidly. For practices offering company secretarial services, confirmation statement filings, or any other Companies House submissions on behalf of clients, this is a compliance action item, not a future planning consideration.

What Has Already Changed: Identity Verification

Identity verification at Companies House became mandatory on 18 November 2025 for all company directors, persons with significant control (PSCs), and certain others registering or being appointed to UK companies.

From this date, anyone incorporating a new company or being appointed as a director or PSC must complete identity verification — either directly through Companies House’s own service or through a registered ACSP acting on their behalf. Without verified identity, the filing is rejected.

This has two immediate implications for practices. First, any client seeking to incorporate a new company, appoint a new director, or register a new PSC needs their identity verified before the filing can proceed. Second, the most efficient route for practices handling multiple filings is to be registered as an ACSP — this allows the practice to verify client identity on behalf of Companies House as part of the filing workflow, rather than directing every individual to the separate GOV.UK verification portal.

What Is an ACSP?

An Authorised Corporate Service Provider is a business registered with Companies House that is permitted to: verify the identity of clients for Companies House purposes, file information at Companies House on behalf of clients, and carry out other authorised activities within the company secretarial workflow.

To register as an ACSP, the firm must be supervised by a recognised Anti-Money Laundering supervisory body — such as ICAEW, ACCA, ICAS, or HMRC’s AML supervision service. This links directly to the AML supervision requirements that also underpin HMRC’s mandatory tax adviser registration (effective May 2026). A firm that has not sorted its AML supervision status is blocked from both.

ACSP registration opened to third-party providers from 18 March 2025. Practices that registered early are already operating as ACSPs. Those that have not yet registered should treat this as a priority — particularly given the November 2026 mandatory deadline.

The November 2026 Filing Deadline: What It Means in Practice

From no earlier than November 2026, businesses must be registered as an ACSP to file information for clients at Companies House. “Filing information” covers the full range of company secretarial submissions: confirmation statements (CS01), officer appointments and resignations, PSC changes, registered address updates, and any other statutory filing.

The consequence of not being registered by this deadline is stark: practices that are not ACSPs will not be able to submit these filings for clients. Clients requiring confirmation statement filings — an annual obligation for every UK limited company — will either need to file directly themselves or find a registered ACSP to act for them. For practices with a significant company secretarial workflow, this is a business-critical compliance step.

The phrase “no earlier than November 2026” reflects that the exact date has not yet been specified — it will be confirmed in advance by Companies House. Practices should not use this ambiguity as a reason to delay registration.

The ACSP Registration Checklist

To register as an ACSP, your practice needs to complete the following:

Confirm AML supervision is in place
Your firm must be registered with a recognised AML supervisory body. This is a hard prerequisite for ACSP registration. If AML supervision is not current, resolve this first. It is also required for HMRC’s mandatory tax adviser registration from May 2026 — sorting one addresses both.
Complete the ACSP registration application via Companies House
The application requires information about the firm’s structure, the senior individuals within it (who must complete their own identity verification), and confirmation of AML supervision status. Applications are made through the Companies House online portal.
Verify the identity of key individuals
Senior role-holders within the practice — directors, partners, and equivalents — must complete identity verification as part of the ACSP registration process. This is the same verification required of company directors under the broader reforms.
Confirm ongoing maintenance obligations
ACSPs must inform Companies House of any changes to the information submitted within 14 days of the change. The ACSP must also maintain continuous AML supervision — if supervision lapses, the ACSP registration is invalid.
Update your client onboarding process
Once registered as an ACSP, your practice can verify client identity as part of your onboarding workflow. This is more efficient than directing clients to the GOV.UK portal and allows you to control the verification process and retain evidence.

Identity Verification in Practice: Client Onboarding

For clients who need their identity verified — either for a new incorporation, a new directorship, or a PSC registration — the ACSP route is the most practical for practices handling volume. Through BrightChecks, practices can run identity verification for clients as part of onboarding, generating a verified identity status that can be used for Companies House filings. This replaces the manual, client-directed approach and creates a consistent, auditable verification record.

For clients who have not yet had their identity verified and are existing directors or PSCs of UK companies: voluntary verification opened in April 2025. While the deadline for existing officeholders has not yet been confirmed, early verification reduces the risk of last-minute complications and positions the practice as proactive on compliance.

Inform Direct: Company Secretarial Filing for ACSP-Registered Practices

For practices already offering or expanding into company secretarial services, Inform Direct automates the full range of Companies House filings — CS01 confirmation statements, officer changes, PSC register updates, and more — in a single platform designed for multi-company management. Once registered as an ACSP, practices using Inform Direct can integrate the ACSP filing capability into their existing workflow, managing all statutory filings alongside identity verification records from one place.

This content may have been developed with the assistance of AI tools. Content is reviewed by a member of the Bright team before publication. Guidance on legislation can be obtained from your industry body.