Economic Crime and Corporate Transparency Act 2023 - Changes in Companies House

The timeline for these new measures is as follows: 

Going forward, an ACSP will need to register as such before it can submit information and conduct verification checks on behalf of its clients. This will include company formation agents, accountants, solicitors, chartered secretaries and governance professionals. To become an ACSP, agents must be supervised by a UK Anti-Money Laundering (AML) supervisory body. 

Companies House hosted a webinar on 2 April 2025 which shared helpful information on registering as an ACSP. A useful video from Companies House on registering as an ACSP is available here.  

More information on identity verification and ACSP is available in the links below:  

• Identity verification Changes to UK company law  

• Authorised Corporate Service Providers - Changes to UK company law 

Other changes to be introduced later  

There are other large and complex changes that will be introduced in phases over the coming years. Some of these changes are outlined below.  These are outlined in the transition plan available on Gov.uk.  

Failure to prevent fraud offence

We draw attention to the inception of the “failure to prevent fraud” (FTPF) offence which comes into force on 1 September 2025. ECCTA provides that the UK Secretary of State must issue guidance about procedures before the provisions come into force. This guidance to organisations on the offence of failure to prevent fraud was issued on 6 November 2024. The guidance stated that the offence will come into effect nine months after the publication of the guidance, to allow organisations to develop and implement their fraud prevention procedures. 

The FTPF offence applies to large organisations (including groups) across all sectors as per the UK Companies Act 2006. The legislation will apply to large organisations where an associate of the organisation commits any of the offences listed in schedule 13 of the ECCTA (for example, cheating the public revenue or false accounting) with the intention of benefitting the organisation and the organisation did not have in place reasonable fraud prevention procedures.

Company thresholds changed with effect from 6 April 2025. Please click to access our UK company law thresholds webpage. As such, from 6 April 2025 the thresholds will be as follows:  

• More than 250 employees. 

• More than £54m turnover. 

• More than £27m total assets.   

It is noted that an Irish entity with business operations in the UK may be within scope and should be carefully considered. 

Filing accounts by software only

Companies House will soon be transitioning towards filing accounts by software only. This will allow more efficient and secure filings for companies and will improve the quality of the data on the register. Software-only accounts filing will create a single, cost-effective, sustainable and traceable way to file.  

The new legislation lays the foundation for Companies House to require companies to file accounts in a digital format. To comply with these changes, all companies will need to find suitable software before web-based and paper filing options are no longer available.  

This applies to directors who file accounts themselves, and companies who use third party agents or accountants to file their annual accounts. It is anticipated that the move to filing accounts by software only will be phased in over the next 2 to 3 years.  

Changes to small company filing options

Companies House intends streamlining the accounts filing options for small and micro-entity companies.

Small and micro-entity companies will need to file their profit and loss accounts. The detail of what they will need to include will be set out in secondary legislation. 

Small companies that do not qualify as micro entities will also need to file a directors’ report. It will also be removing the option to file ‘abridged’ accounts.  

Read about changes to small company accounts filing options and find out more about the measures in the Economic Crime and Corporate Transparency Bill factsheet.  

Phase 1 measures – March 2024 

On 4 March 2024, Companies House introduced the first set of changes which include:  

1. new rules for registered office addresses. 

2. a requirement for all companies to supply a registered email address.  

3. new lawful purpose statements. 

These changes apply to incorporated entities, limited partnerships and limited liability partnerships. It will also apply to their members and directors.  

It is also noted that Companies House fees increased from 1 May 2024.  

1. New rules for registered office addresses

The new rules for registered office addresses mean companies must, at all times, have an “appropriate address” as their registered office.  

An address is an “appropriate address” if, in the ordinary course of events:  

• a document addressed to the company, and delivered there by hand or by post, would be expected to come to the attention of a person acting on behalf of the company. 

• the delivery of documents there is capable of being recorded by the obtaining of an acknowledgement of delivery. 

These changes mean you will not be able to use a PO Box as your registered office address. Companies House has noted it will take enforcement action against companies that do not have an appropriate registered office address.  

2. A requirement for all companies to supply a registered email address

Under ECCTA, all companies will need to provide a registered email address. Companies House will use this email address to communicate with the company and have noted it will not be made available to the public.  

New companies will need to give a registered email address when they incorporate. Existing companies needed to give a registered email address when they file their next confirmation statement, with a statement date from 5 March 2024 onwards.  

3. New lawful purpose statements

There is a new requirement for those who register or ‘incorporate’ a company from 4 March 2024. The subscribers to the company will need to confirm they’re forming the company for a lawful purpose.  

A company will also need to confirm its intended future activities are lawful, on their annual confirmation statement. This applies to all confirmation statements with a statement date from 5 March 2024 onwards.  

Other resources 

Over the past number of months, much has been issued in terms of commentary and advice on the introduction of these changes from various sources. We have assembled below some information that may be of assistance to members. 

The below is a summary of the questions and answers from a webinar hosted by Companies House in April 2025:  

Question: Will a director of multiple companies need to verify their details for each appointment? 
Answer: The director will only need to verify their identity once but will need to provide their unique identifier (personal code) and a statement for each appointment they hold.  

Question: Is the fee a once off fee or it is to be paid annually? 
Answer: The fee is a once off registration fee of £55.  

Question: Is there a dedicated telephone number to ask general questions about IDV and becoming an ACSP? 
Answer: There is no dedicated telephone number, however, the customer care team at Companies House are prepared to deal with all enquiries. 

Question: What are the most appropriate links to assist with registration? 
Answer: You can read guidance on applying to register as a Companies House authorised agent, you can also find more information on changes to UK company law website and the Companies House blog is also a useful resource. 

Question: Who needs to apply to be an ACSP? 
Answer: An Authorised Corporate Service Provider (ACSP) is a third-party provider that is covered by Money Laundering Regulations. For example, this could be a Professional Service Provider (e.g., accountants and solicitors) and Trust and Company Service Provider (e.g., company formation agents).

Question: Who needs to apply to be an ACSP?  
Answer: An Authorised Corporate Service Provider (ACSP) is a third-party provider that is covered by Money Laundering Regulations. For example, this could be a Professional Service Provider (e.g., accountants and solicitors) and Trust and Company Service Provider (e.g., company formation agents).

To become an ACSP, agents must be supervised within the UK by one of the relevant Anti-Money Laundering (AML) Supervisory Bodies, such HMRC, Financial Conduct Authority, The Gambling Commission. There are 25 supervisory bodies in the UK in total which are listed here.  

Question: How long will an application take to be approved or rejected?

Answer: Timings for approval will depend on how easily Companies House can identify whether applicants are supervised by an Anti Money Laundering (AML) body. This process can take longer if further checks are required.

Question: Why might an ACSP application be rejected? 

Answer: A common reason for rejection is a failure to match the applicant to their relevant supervisory body. To avoid this, check your AML membership number (also known as an AML ID number) is correct before starting your application.

Question: Once registered, do I use the ACSP account to file with Companies House straight away?

Answer: Once you're registered as an ACSP and your account has been approved, you can start verifying your clients' identities for Companies House using the Verify a client service.

Question: Can I add other employees in my organisation to the ACSP account?

Answer: Once the ACSP account has been approved, other employees can be added. These employees will not have to verify their identity, but will be able to carry out services on behalf of the ACSP, such as identity verification checks and filing accounts for clients.

Question: Once registered, can an ACSP outsource the completion of identity verification checks to a third party?

Answer: Yes, you can outsource identity verification to a third party, but the ACSP will still be responsible for making sure the checks meet Companies House requirements.

ACSPs should check what evidence they need to provide to Companies House when they submit a verification statement. They should also keep records so that evidence can be supplied and checked on request.

Question: Where would I find the “AML Membership Number”? 
Answer: Depending on your supervisory body, you should be able to find your AML Membership Number on your practising certificate, communications from the supervisory body, the supervisory body’s online register. Your AML supervisory body may have a different name for it, such as a firm ID or number, a regulation ID, an AML ID. You should contact the AML supervisory body if you need to check your details.

Question: Will a director be charged a fee when they do their ID check?  
Answer: No, it is free to verify using GOV.UK One Login. 

Question: When can companies register as an ACSP?  
Answer: Both companies and sole traders can register as an ACSP. For registered companies, someone who holds a senior role within the business, such as a director, will need to complete the registration process.

Question: Does a current director of a limited company have to register now?  
Answer: Directors do not need to register as an ACSP but they will need verify their identity. Individuals will be able to voluntarily verify their identity from 8 April. In autumn 2025, this will become a legal requirement.

Question: Do you need to register if you already have an Agent Assurance Code?  
Answer: Yes, all third-party providers will need to register their business as an ACSP before they can submit information and carry out identity verification checks on their clients.

Question: How long will it take for the application to be approved? 
Answer: This depends on how quickly Companies House can check the details with the applicant’s supervisory body. 

Question: We input our AML Membership Number but the ACSP application was rejected. Please advise.  
Answer: We recommend checking that the details your AML supervisory body holds for your company match those that Companies House hold on its company register for your limited company. These need to match in order for the application to be approved.

Question: Do accountants need to do an ID verification on all clients, even if the client does it directly with Companies House? 
Answer: If your clients verify directly with Companies House via GOV.UK One Login, you won't need to also verify them. The client will need to provide you with their personal code if they want you to continue filing on their behalf. From spring 2026, however, anyone filing information on behalf of another company will need to be registered as an ACSP. We will share more information in advance of this being introduced.

Question: Do you need a separate email address for each person you are verifying? 
Answer: Yes, as they will receive their personal code to that email address.

Question: Will a Company Secretary need to be registered as they file on behalf of their company?  
Answer: Officers and employees of a company will not need to register as an ACSP to file on behalf of their company. However, they will need to verify their identity when this becomes a requirement in Autumn 2025. Identity verification will become compulsory for new directors and people with significant control (PSCs), existing directors and PSCs and anyone acting on behalf of a company. 

Frequently asked questions - Phase 1 measures – March 2024 

The below is a summary of the questions and answers from a webinar hosted by Companies House:

Question: Will the registered email address replace eReminders?
Answer: The email reminders service is separate from the requirement to have a registered email address for your company. 

Question: Will my registered email be visible on Companies House website?
Answer: No, the company's registered email address will not be published on the Companies House register. 

Question: Does the registered email address have to be that of an individual person? Or can a generic email address (i.e. companysecretary@company) be used? 
Answer: The registered email address can be your personal email address or a corporate email address, so long as it meets the conditions of being an appropriate address. 

Question: Will the registered email address have to be one for an officer of the company or can an agent's email address be provided for that purpose? 
Answer: A company can use an agent’s email address as long as it’s appropriate. An appropriate email address is one at which, in the ordinary course of events, emails sent to it by the registrar would be expected to come to the attention of a person acting on behalf of the company.

Question: Can a company register more than one registered email? For example - one email address for the company's in-house company secretarial team and one email address for its service provider? 
Answer: You can only register one registered email address. You can, however, register up to four email addresses for email reminders. 

Question: Can law firm or accountancy firm addresses be the registered office address for a company / multiple companies? 
Answer: Yes - There is also nothing to prevent the same office address being used for more than one company, as long as it meets the criteria as being appropriate, so if you’re the director of multiple companies, or an accountant with lots of different clients. you could use the same registered office address for them all. 

Question: What is the thinking behind the introduction of the annual “confirmation of future lawful intent” requirement? 
Answer: The intention of these new statements is to make it clear that all companies on the register, new and existing, have a duty to operate in a lawful way. Companies House may take sanction or enforcement action against your company if it receives information that confirms you are not operating lawfully.  

Question: Who is responsible for "lawful purpose" statement on IN01 - subscribers, first officers or formation agents? 
Answer: The subscribers to the company will need to confirm they are forming the company for a lawful purpose. The company will then need to confirm its intended future activities are lawful, on their annual confirmation statement. 

Question: Are these changes intended to apply to LLPs and companies with a UK branch? 
Answer: The new legislation generally applies to all entities registered with Companies House, which includes LLPs and overseas companies. More information here - Who is affected by the changes - Who is affected by the changes (changestoukcompanylaw.campaign.gov.uk). 

Question: Will the software-only filing of accounts apply to dormant company accounts as well? 
Answer: All web-based and paper filing routes will no longer be available, and all companies will need to find suitable software to comply with these changes. These changes will apply to all companies and all accounts types. 

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