Companies House: New Enforcement Powers & Mandatory ACSPs for Accountants
By ComplyPost
The Economic Crime and Corporate Transparency Act (ECCTA): A New Regulatory Era
The landscape of UK corporate compliance is undergoing its most significant transformation in over a century, driven by the Economic Crime and Corporate Transparency Act (ECCTA) 2023. This landmark legislation, which received Royal Assent in October 2023, fundamentally redefines the role of Companies House. No longer a passive repository of information, Companies House is now an active and powerful regulator, equipped with substantial Companies House enforcement powers to combat economic crime and enhance corporate transparency.
For UK accounting practices, these ECCTA regulatory changes represent a critical shift. The Act introduces stricter compliance obligations for companies and, crucially, new requirements for professional agents who interact with Companies House on behalf of clients. A central pillar of these reforms is the mandatory requirement for many accountants to register as Accredited Corporate Service Providers (ACSPs).
Companies House's Enhanced Enforcement Powers: What Accountants Need to Know
Companies House has been granted a suite of robust new powers, designed to ensure the accuracy and integrity of the UK's company register. These powers move beyond simple record-keeping, allowing the Registrar to proactively scrutinise, query, and even reject filings.
- Power to Query and Reject Filings: The Registrar can now challenge information submitted if it appears inconsistent, incorrect, or suspicious. They can request additional evidence to support filings and reject those that don't meet new standards.
- Stronger Powers to Remove Information: Companies House has expanded capabilities to remove or correct inaccurate, misleading, or fraudulent information from the register, even retrospectively. This ensures the public record is reliable.
- Increased Fines and Penalties: The financial consequences for non-compliance are significantly higher. Companies House can now issue much larger fines, with penalties for certain offences reaching up to £10,000. These can be imposed directly without needing a court order in many cases.
- Striking Off Companies: Companies House has the power to strike companies off the register itself if they consistently fail to meet their obligations or are found to be vehicles for abuse or economic crime.
- Proactive Data Sharing: New powers allow Companies House to proactively share data with law enforcement agencies and other public authorities to assist in preventing and detecting economic crime.
These enhanced powers are underpinned by new statutory objectives for the Registrar, focusing on ensuring documents are delivered properly, the register is complete and accurate, minimising misleading entries, and preventing unlawful activity.
Increased Scrutiny and Data Integrity on the Register
The drive for greater transparency extends to several key areas of company information. Accountants must advise clients on these stricter requirements to avoid penalties and ensure compliance.
Registered Office and Email Address Obligations
Companies are now required to maintain an 'appropriate address' as their registered office, meaning a PO Box address is no longer permitted. This address must be where a company can genuinely receive physical mail and where its records can be inspected. Additionally, all registered entities must provide a registered email address, which Companies House will use for official communications.
Stricter Checks on Company Names
Companies House will apply stronger checks on company names to prevent those that appear suspicious, could facilitate crime, or suggest a false connection with a foreign government or international organisation. This is part of maintaining the integrity of the public register and fostering trust in the UK business environment.
Failure to Prevent Fraud Offence
While primarily impacting larger organisations, the ECCTA introduces a new corporate criminal offence of 'failure to prevent fraud', which came into force on 1 September 2025. Organisations may be liable if an employee or associated person commits fraud intending to benefit the organisation, and the organisation did not have reasonable fraud prevention procedures in place. This highlights the broader push for robust compliance across the corporate sector.
Mandatory Identity Verification for Directors and PSCs
A cornerstone of the ECCTA reforms is the new requirement for all company directors, People with Significant Control (PSCs), and LLP members to verify their identity with Companies House. This measure is designed to make it significantly harder for individuals to set up or control companies anonymously for fraudulent purposes.
- Commencement Date: Identity verification became a legal requirement from 18 November 2025. This date marked the start of a 12-month transition period, not a hard deadline for everyone.
- New Directors/PSCs: Individuals appointed as new directors or PSCs from 18 November 2025 onwards must verify their identity at the point of appointment or incorporation.
- Existing Directors: Existing directors (appointed before 18 November 2025) must verify their identity before their company files its next confirmation statement due after 5 March 2026. The absolute hard deadline for all existing directors is 18 November 2026.
- PSCs: Once a PSC has verified their identity and received a personal code, they have 14 days to provide it to Companies House.
- Verification Methods: Individuals can verify their identity directly with Companies House via the GOV.UK One Login service using approved photo ID. Alternatively, they can use an Accredited Corporate Service Provider UK (ACSP) to complete the verification on their behalf.
Non-compliance with identity verification is a serious offence, potentially leading to criminal charges, fines, imprisonment, and rejection of company filings.
Becoming an Accredited Corporate Service Provider (ACSP) for Accountants
For accounting firms and other professional agents who file documents with Companies House on behalf of clients, the most direct impact of the ECCTA is the mandatory requirement to become an Accredited Corporate Service Provider (ACSP), also known as a Companies House authorised agent.
This new status is crucial for maintaining compliance and continuing to offer essential services to your clients. The change aims to ensure that all intermediaries submitting information to the register are properly vetted and supervised for anti-money laundering (AML) purposes, thereby bolstering the integrity of the UK's corporate data.
Key takeaway: If your practice files company formations, confirmation statements, or any other documents with Companies House for clients, you will need to be a registered ACSP. Unregulated agents will no longer be able to file on behalf of clients.
The ACSP Application Process and Ongoing Obligations
The journey to becoming an ACSP involves specific steps and ongoing responsibilities. Companies House opened ACSP registration on 24 March 2025, with a fee of £55.
Eligibility Requirements
To register as an ACSP, your firm must meet strict criteria:
- AML Supervision: Your business must be supervised for AML compliance by a recognised UK Anti-Money Laundering (AML) supervisory body. This includes bodies such as HM Revenue & Customs (HMRC), the Financial Conduct Authority (FCA), or professional accountancy bodies like ACCA.
- Senior Role Application: The application must be made by an individual in a senior role within your practice, such as a director, partner, or sole practitioner.
The Application and Authorisation
Once registered and approved, Companies House will set up an authorised agent account and issue your firm with agent codes. This system is designed to be similar to HMRC's agent codes for tax agents, streamlining the filing process for verified professionals.
Ongoing ACSP Obligations
Becoming an ACSP is not a one-off event; it comes with continuous responsibilities:
- Maintain AML Supervision: You must continuously maintain your registration with at least one AML supervisory body.
- Notify Companies House of Changes: Any changes to the information Companies House holds about your firm (e.g., firm name, AML supervisory body) must be reported within 14 days. Failure to do so is an offence.
- Record Keeping: If your firm verifies clients' identities for Companies House, you must keep records of these identity checks for seven years.
- Compliance with Requests: You must provide additional information if requested by Companies House regarding your filings or identity checks.
Breaches of these legal requirements can lead to account suspension, publication on a suspension list, fines, or even criminal prosecution.
When ACSPs Become Mandatory for Filing
While ACSP registration has been open since March 2025, the mandatory requirement for ACSPs to file on behalf of clients was originally anticipated for Spring 2026. However, Companies House has announced delays, and this change will now not take place before November 2026. Until then, filing procedures remain unchanged.
Preparing Your Practice for the New Companies House Landscape
The transition to a more proactive Companies House and the mandatory ACSP regime requires careful preparation from accounting and bookkeeping firms. Proactive steps now can ensure a smooth transition and continued compliance.
1. Assess Your Current Processes
Review how your firm currently handles company secretarial services and Companies House filings. Identify any gaps in your procedures that might not align with the new requirements, particularly around client onboarding, identity verification, and data accuracy. Consider how digital tools can streamline your registered office obligations and filing processes.
2. Prioritise ACSP Registration
If your firm files on behalf of clients, initiate your ACSP registration process without delay. Ensure your firm is fully compliant with AML compliance regulations and supervised by a recognised body. The fee is £55, and early registration will prevent disruption once the mandatory filing date arrives (no earlier than November 2026).
3. Understand Director Identity Verification Deadlines
Communicate clearly with your clients about the mandatory director identity verification UK requirements. Help them understand their specific deadlines (new directors at appointment, existing directors by confirmation statement, PSCs within 14 days of verification). Offer your services as an ACSP to facilitate their identity verification, especially for overseas directors or those without suitable UK photo ID.
4. Update Client Engagement Letters and Terms
Ensure your client engagement letters reflect the new regulatory environment, including the increased due diligence requirements, identity verification processes, and any changes to service fees due to the enhanced compliance burden and increased Companies House fees (e.g., confirmation statement digital filing fee increased to £50 from 1 February 2026).
5. Staff Training and Awareness
Educate your entire team on the ECCTA changes, the new Companies House enforcement powers, and the firm's responsibilities as an ACSP. Regular training will ensure everyone understands the importance of data accuracy, verification procedures, and the consequences of non-compliance.
6. Leverage Digital Compliance Solutions
Modern compliance platforms can significantly ease the burden of these new regulations. Digital tools can help manage client identity verification, track filing deadlines, ensure accurate data submission, and maintain the necessary audit trails for ACSP record-keeping. Integrating these solutions can enhance efficiency and reduce the risk of errors or missed deadlines.
Embracing a More Robust Compliance Environment
The Economic Crime and Corporate Transparency Act marks a pivotal moment for UK corporate governance. Companies House is transitioning into a powerful, proactive regulator, committed to improving the transparency and reliability of the UK register. This means a more stringent environment for companies and, by extension, for the accountants and bookkeepers who support them.
While the changes, including increased Companies House fines 2026 and the mandatory ACSP registration, present new challenges, they also offer an opportunity. Firms that embrace these reforms, invest in robust compliance procedures, and leverage digital tools will not only meet their legal obligations but also reinforce their reputation as trusted and diligent advisors in a more transparent business world.
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