Technical Hub

Introduction The Economic Crime and Corporate Transparency Act  (ECCTA) which was passed in 2023 continues to bring legal change in the UK. ECCTA introduced identity verification requirements so that UK Companies House will know the identity of anyone setting up, running ,owning or controlling a company in the UK. As part of those changes, ECCTA also introduced the ACSP regime into UK law . A few  strands of the regime, including registration as an ACSP and performing verification and filing are considered in this article. We also consider some challenges which have arisen for our member firms in cases where they are not eligible to register as an ACSP, and we explore further if there are any solutions member firms can adopt. ACSPs :Verification and filing Since 18th November 2025 company directors and people with significant control (PSCs) are legally required to verify their identity under ECCTA. A 12-month transition period is now in place for existing directors and PSCs to comply with the new identity verification requirements by November 2026. The date during the transition period by which directors/PSCs must verify will depend on various factors. This includes whether they are a new director, in which case  they must comply before their registration or appointment as a new director. Existing directors or PSCs must comply based on the company confirmation statement due date during the transition period (and compliance by November 2026 is required). Failure to comply with identity verification requirements on time is an offence. Directors and PSCs can (1) verify themselves directly with Companies House or (2) verify by using an ACSP. Firms which are eligible to register with Companies House as an ACSP (see further below) have been able to register as ACSPs since 18 March 2025. If an accountancy firm  wants to verify its client company directors or PSCs then it must be registered now as an ACSP . Currently there is no change to filing procedures for Companies House and firms can continue to file documents with Companies House in the usual way for their clients without being registered as an ACSP. This will change later in 2026 . In January 2026, Companies House indicated that from no earlier than November 2026, firms will need to be registered as an ACSP to be able to file on behalf of clients. What firms can register with Companies House as an ACSP To become an ACSP, a firm must be supervised within the UK under the UK's Money Laundering Regulations 2017 (the Regulations) by a relevant Anti-Money Laundering (AML) supervisory body. See further details in the following paragraph. What if you cannot register with Companies House as an ACSP The roll out of identity verification and the ACSP regime has given rise to an issue for some Chartered Accountants Ireland member firms which are not AML supervised in the UK . Schedule 1 of the Regulations lists Chartered Accountants Ireland as an AML supervisory authority in the UK in relation to certain "relevant persons", namely relevant persons who are members of the Institute or who are regulated or supervised by it (Regulation 7). The Regulations apply to relevant persons acting in the course of business carried on by them in the United Kingdom. For the purposes of the Regulations a relevant person is to be regarded as carrying on business in the UK where their registered office is in the UK and the day-to-day management of the carrying on of the business is the responsibility of that office, or another establishment in the UK (Regulation 9). Republic of Ireland registered firms may have clients for whom they need to file with Companies House, but if the member firm is supervised for AML purposes in Ireland, not the UK under the Regulations then it is not eligible to register as an ACSP under the legislation as it stands.  In July 2025, the Institute made a representation to the UK Secretary of State for Business and Trade about this issue and for a change in the law to allow Irish AML supervised firms to apply to register as ACSPs. The issue has not yet been resolved to date , and the Institute continues to advocate for this change. If a member firm cannot register because it is not UK AML supervised (firms can check their status with the Institute ) then it might consider putting an arrangement in place with a third party registered  ACSP to carry out verification or filing work on behalf of its clients. If this option is used by member firms, it is considered outsourcing and appropriate outsourcing controls should be implemented by member firms including (1) performance of due diligence regarding the third party registered ACSP prior to appointment, (2) establishment of an outsourcing agreement with the third party ACSP including arrangements regarding information sharing requirements (3) post appointment, the member firm should perform on-going oversight of verification and/or filing activities performed by the third party ACSP on its behalf. The Institute does not endorse or recommend third party ACSPs and we urge members who are considering this route to give careful consideration to the guidance issued by Companies House on the list of ACSPs which it maintains . Members should study the article in full. Please note some of the highlights: the list is not a complete list of all registered ACSPs , it is not updated on a set schedule by Companies House so it may be incomplete or out of date. In addition , before a member  uses a third party ACSP they should always check that the ACSP is not on the list of ceased or suspended ACSPs. The work involved in verification to Companies House by an ACSP  An eligible firm may be considering expanding its offering by registering as an ACSP and taking on new business of verifying directors/PSCs for companies . Before undertaking this work, firms should satisfy themselves as to what is involved. For an ACSP to verify a client , Companies House requires ACSPs to have completed identity checks that meet the Companies House identity verification standard. It is important to note that these are different to customer due diligence checks to prevent money laundering. You can click to read guidance on how to meet Companies House identity verification standard. This includes asking for information about the person, getting  evidence to verify the person’s identity and the documents which can be used as evidence. It also covers the checking of identity documents either electronically by identification document validation technology (IDVT) or checking by a person . If this checking is by a person they must be trained in detecting false documents and be familiar with the guidance on examining identity documents to detect basic forgeries. The requirements to verify documents ,laid out in the guidance, is a significant step up from what is acceptable under anti money laundering  legislation. These checks and verifications will take time and may involve investment in technology or upskilling of people. All of this has  cost implications and will impact those practices which decide to register as ACSPs. Such firms must enhance their procedures and training and plan for this uplift in good time. Acting as an ACSP and performing verification and identity checking may be viable for a firm’s existing clients where the firm already knows much about the client . However , firms must give some pause for consideration of whether there is merit and the cost effectiveness of registering as an  ACSP to take on new business versus the risks which could potentially exist with this new business . Accountancy  firms  should perform their own risk assessment when deciding if they will take on this new business and firms should also ensure that the service is covered under their PII policy. Reminder to member firms to register as an ACSP If an eligible firm is willing to undertake the work involved in being an ACSP and is planning to verify the identity of its client directors and PSCs or wishes going forward to file information at Companies House on behalf of clients (or both) , it must  register to be an ACSP. Eligible firms are encouraged to register now and you can click to read more about how to register as a Companies House authorised corporate service provider and  Applying to register as a Companies House authorised agent - GOV.UK Firms are reminded that - To register you must be supervised for AML in the UK, - When completing the application process, you will be asked to provide your firm identity number, that will be your Institute firm number. Please ensure that the firm’s business name, address and any trading names provided to Companies House match what is recorded with the Institute, otherwise your application may be delayed, -A member’s name and membership number should not be used as the Institute’s authorisation for AML supervision is granted to firms not individuals , -if a sole practitioner is applying for authorisation, please use the unincorporated firm option, - You will be asked to complete identity verification as part of the application process, - There will be a registration fee of £55, payable to Companies House, - Once you are registered, you will be provided with a new digital account and unique identity number. This will allow you to file information and complete identity verification for your clients. This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.  

The Pensions Research Accountants Group (PRAG) has finalised its amendments to the Pension Statement of Recommended Practice (Pension SORP). The updated “Statement of Recommended Practice, Financial Reports of Pension Schemes 2026” will be effective for periods commencing on or after 1 January 2026. PRAG are a leading independent industry body working for the development of occupational pension schemes. Their focus is on financial reporting and internal control, and they are the Financial Reporting Council’s (FRC’s) recognised SORP-making body for Pension Schemes. The Pension SORP was last updated in 2018 and since then, the FRC has made amendments to FRS 102. There have also been several industry developments which impact on pension scheme financial reporting as well as changes to pensions legislation and regulations. In 2025, PRAG held a consultation on its proposed amendments to the SORP. A copy of Chartered Accountants Ireland’s response is here. The following resources are available on PRAG’s website; News item discussing the updated Pension SORP Upcoming free webinar A copy of the updated Pension SORP will be available to purchase in due course.

From the Professional Accountancy team…... The Institute held three in-person events in early March 2026 in Cork, Galway and Dublin. Sarah Jane O’Keeffe, Partner in Azets, and Derek Wilson, former inspector in the Institute presented at the well-attended events and provided attendees with great practical examples. Attendees were given a comprehensive overview of the Creditors Voluntary Liquidation Handbook  published last year to assist Liquidators in complying with legislative and Statement of Insolvency Practice (SIP)  requirements when conducting statutory meetings, reporting to creditors and approval of remuneration. The sessions also covered compliance matters and potential issues and problems that can arise and how to avoid or best navigate these.  Attendees were also reminded of the resource available from the Corporate Enforcement Authority the form of the Liquidator’s report on conduct of directors in a winding up of an insolvent company. Finally, readers are reminded to check out the Professional Accountancy Team’s Technical Hub which includes a dedicated Insolvency section and to keep up to date with other technical material also. This information is provided as resources and information only and nothing in these pages purports to provide professional advice or definitive legal interpretation(s) or opinion(s) on the applicable legislation or legal or other matters referred to in the pages. If the reader is in doubt on any matter in this complex area further legal or other advice must be obtained. While every reasonable care has been taken by the Institute in the preparation of these pages, we do not guarantee the accuracy or veracity of any resource, guidance, information or opinion, or the appropriateness, suitability or applicability of any practice or procedure contained therein. The Institute is not responsible for any errors or omissions or for the results obtained from the use of the resources or information contained in these pages.