Companies House: Navigating the New 'Fit and Proper' Rules for ACSPs (August 2026)

The landscape of UK corporate compliance is continually evolving, driven by the imperative to combat economic crime and enhance transparency. A pivotal development for accountancy and bookkeeping practices is the recent guidance issued by Companies House on 11 August 2026, which clarifies the 'fit and proper' criteria for Authorised Corporate Service Providers (ACSPs). This guidance is not merely an administrative update; it represents a significant strengthening of regulatory oversight, with direct implications for your firm's ability to operate and serve clients effectively.

For UK practice managers and compliance officers, understanding these updated standards for Companies House ACSP fit and proper status is paramount. Failure to meet these rigorous requirements can lead to severe consequences, including the suspension or cessation of your ACSP registration. This post will delve into the specifics of this new guidance, outlining the criteria, the role of the Economic Crime and Corporate Transparency Act 2023 (ECCTA), and practical steps your firm can take to ensure robust and ongoing compliance.

Understanding the Authorised Corporate Service Provider (ACSP) Regime

The concept of an Authorised Corporate Service Provider (ACSP) was introduced by the landmark Economic Crime and Corporate Transparency Act 2023 (ECCTA). ACSPs are a new category of regulated professionals, primarily accountants, solicitors, and company formation agents, who are authorised by Companies House to perform specific functions. Their core responsibility is to verify the identities of company directors, LLP members, persons with significant control (PSCs), and other individuals involved in UK companies.

This identity verification (IDV) process is crucial for enhancing the reliability of the Companies House register and preventing the misuse of UK corporate structures for illicit activities. From November 2025, identity verification became mandatory for new directors and PSCs at incorporation, with a 12-month transition period for existing ones. By Spring 2026, it became compulsory for the presenter of any filing at Companies House to have their identity verified. The ECCTA also stipulates that any third-party agent filing on behalf of others must be a registered ACSP, a requirement expected to fully come into effect no earlier than November 2027 for all filings.

The ECCTA 2023: Foundation for Enhanced Corporate Transparency

The ECCTA 2023, which received Royal Assent on 26 October 2023, represents the most significant reform to Companies House in decades. Its overarching goal is to strengthen corporate transparency, combat economic crime, and ensure a more reliable public register. The Act grants Companies House enhanced powers to query, reject, and remove information from the register, as well as to investigate and share data with law enforcement.

Beyond IDV, the ECCTA also introduced other critical changes, such as new requirements for an 'appropriate' registered office address and the mandatory provision of a registered email address for companies. These interconnected reforms underscore a broader governmental push for greater accountability and integrity across the UK business environment. Your firm's adherence to these evolving standards is fundamental to maintaining its licence to operate within this new framework.

Companies House ACSP Fit and Proper Criteria: A Detailed Breakdown

The new guidance published on 11 August 2026 by Companies House provides specific details on how the Registrar will assess whether an applicant or an existing ACSP is 'fit and proper' to carry out their functions, as mandated by section 1098B of the Companies Act 2006. This assessment is continuous, applying both at the point of registration and throughout an ACSP's operational lifespan.

Companies House will consider all relevant circumstances, taking into account the seriousness, timing, and resolution of any concerns. The guidance identifies four principal areas of assessment:

1. Eligibility and Competence

AML Supervision: The ACSP (or applicant) must have, and continuously maintain, appropriate anti-money laundering (AML) supervision by a recognised UK supervisory body (e.g., ICAEW, ACCA, AAT, HMRC). It is crucial to note that simply being AML-supervised does not automatically satisfy the 'fit and proper' test.
Suitability: Companies House will assess the ACSP's overall suitability to carry out its functions. This includes scrutinising whether any entity connected with the ACSP, such as a limited company, has been dissolved, is being struck off the register, or is subject to insolvency proceedings. Previous suspensions or cessations of ACSP status, and the conduct leading to them, will also be considered.

2. Criminal, Regulatory, and Financial History

Adverse History: Companies House will examine any history of bankruptcy, disqualification as a director, criminal convictions, or regulatory and disciplinary findings against the ACSP or its key personnel.
Statutory Compliance: Serious or repeated failures to meet statutory obligations to Companies House, such as late or inaccurate filings, will be a significant red flag.

3. Honesty, Integrity, and Conduct

Ethical Dealings: The Registrar will evaluate the ACSP's previous dealings with Companies House, looking for evidence of honesty, integrity, and transparent conduct.
Accuracy of Information: Providing false or misleading filings or statements, or failing to disclose relevant information, will be viewed very seriously and can count against an ACSP's 'fit and proper' status.

4. History with Companies House and ACSP Activity

IDV Process: The way an ACSP carries out identity verification, re-verification, and filing activities will be under scrutiny. This includes adherence to Companies House's specific IDV standards.
Record Keeping: Maintaining accurate records of IDV checks for inspection purposes and providing further information to the Registrar upon request are vital obligations.

The Grave Risk of ACSP Suspension by Companies House

Companies House now possesses robust powers to ensure compliance, and they have demonstrated a willingness to use them. As early as October 2025, Companies House began publishing information about suspended and ceased ACSPs, with figures showing dozens of firms temporarily barred or permanently removed from the register by December 2025.

If Companies House is no longer satisfied that an ACSP is fit and proper, they may suspend or cease its registration.

Suspension: This means the ACSP is temporarily barred from acting while issues are investigated or further information is requested. During this period, the ACSP and any associated users cannot file documents or verify identities for Companies House.
Cessation: This is a permanent removal from the ACSP register. A ceased ACSP's online account will be closed, and Companies House will publish its name and the date its status was ceased. Crucially, clients whose identities were verified by the ceased ACSP may be contacted and required to re-verify their identities.

Non-compliance also carries the risk of criminal prosecution and financial penalties for the sole trader or all company directors (or equivalent). This highlights the critical importance of proactive and continuous compliance monitoring.

Proactive Compliance: Implementing Robust Internal Controls

To navigate these stringent new rules and safeguard your ACSP status, a proactive approach to compliance is essential. Your firm should implement and regularly review robust internal controls:

Comprehensive Policies and Procedures: Develop clear, documented policies and procedures for all ACSP activities, particularly identity verification, record-keeping, and document filing. Ensure these align with the latest Companies House guidance and your AML obligations.
Staff Training: Provide mandatory, ongoing training for all staff involved in ACSP functions. This should cover the 'fit and proper' criteria, IDV standards, data protection (including GDPR compliance), and the consequences of non-compliance.
Rigorous Record-Keeping: Maintain meticulous records of all identity verification checks, client due diligence, and communications with Companies House. These records must be readily accessible for inspection.
Internal Monitoring and Audits: Establish a system for regular internal reviews and audits of your ACSP processes. This helps identify and address any compliance gaps before they become significant issues.
Designated Compliance Officer: Appoint a senior individual responsible for overseeing ACSP compliance, ensuring they have the authority and resources to implement necessary controls.

Ongoing Monitoring and Reporting Requirements

The 'fit and proper' assessment is not a one-off event; it's a continuous obligation. ACSPs must actively monitor their ongoing compliance and be prepared to respond to Companies House enquiries.

Stay Updated: Regularly review Companies House announcements, guidance, and legislative updates related to ACSPs and the ECCTA. The regulatory environment is dynamic, and staying informed is critical.
Prompt Reporting: If there are any changes to your firm's AML supervision, key personnel, or any other factor that could impact your 'fit and proper' status, report these to Companies House promptly.
Respond to Enquiries: Be prepared to provide additional information or records to Companies House if requested. Timely and accurate responses are crucial for demonstrating your commitment to compliance and can be a mitigating factor in any assessment.

Leveraging Digital Tools for Seamless Compliance

The complexity and continuous nature of ACSP compliance, particularly identity verification and record-keeping, make digital tools invaluable. Modern compliance software can significantly streamline these processes:

Automated IDV Solutions: Integrate solutions that facilitate robust, Companies House-compliant identity verification checks, often leveraging biometric verification and document scanning.
Centralised Record Management: Use platforms that provide a secure, centralised repository for all client due diligence, IDV records, and Companies House filings. This ensures easy access for audits and simplifies reporting.
Compliance Workflows: Implement software that guides your team through the correct compliance workflows, reducing the risk of human error and ensuring consistency.
Automated Alerts and Reminders: Benefit from systems that provide automated alerts for upcoming deadlines, policy reviews, or changes in regulatory guidance, helping you maintain proactive compliance.

By embracing digital solutions, firms can not only meet their Companies House ACSP fit and proper obligations more efficiently but also enhance their overall AML compliance framework, freeing up valuable time for client service.

Conclusion: A Commitment to Corporate Integrity

The new 'fit and proper' guidance for ACSPs from Companies House, effective 11 August 2026, marks a significant step in the UK's ongoing fight against economic crime. For accountancy and bookkeeping practices, this is not just about meeting a new set of rules; it's about demonstrating a profound commitment to corporate integrity and transparency.

By thoroughly understanding the criteria, implementing robust internal controls, maintaining diligent record-keeping, and leveraging appropriate digital tools, your firm can confidently navigate these changes. Proactive compliance will not only secure your ACSP status but also reinforce your reputation as a trusted and responsible service provider in the UK's evolving regulatory landscape.

Stay informed, stay compliant, and continue to uphold the highest standards in your practice.

Companies House: Navigating the New 'Fit and Proper' Rules for ACSPs (August 2026)