Economic Crime and Corporate Transparency Act 2023 - Changes in Companies House
Introduction
The Economic Crime and Corporate Transparency Act (ECCTA) received royal assent on 26 October 2023, and the provisions of the Act continue to be applied on a phased basis by secondary legislation and regulations. You can access the Economic Crime and Corporate Transparency Act and accompanying press release on the UK government’s website.
The primary aims of the ECCTA are to enhance corporate transparency and reduce economic crime, thereby providing increased benefit to the UK economy, for both businesses and individuals.
The Act gives Companies House the power to play a more significant role in tackling economic crime and supporting economic growth. The measures will lead to improved transparency and more accurate and trusted information on its registers.
These objectives also apply to the Registrar of Companies for Scotland and the Registrar of Companies for Northern Ireland.
Identify verification
There are 2 ways for individuals to verify their identity:
You will be guided through the process and presented with options related to the documents you hold and your preferences on how you wish to share them. This may involve being directed to an app and instruction for this will be given to you at the relevant point within the service.
Directors and PSCs will be able to check the Companies House register to see identity verification due dates for all their roles.
Failure to comply with identity verification requirements on time is an offence and consequences may include financial penalties, referral to The Insolvency Service and prosecution through the court. There is more information on non-compliance available here.
Identity verification requirements for limited partnerships, corporate directors of companies, corporate members of limited liability partnerships, and officers of corporate PSCs, will be introduced at a later date.
The timeline for these new measures is as follows:
Authorised Corporate Service Provider (ACSPs)
Companies House will verify the identity of anyone submitting information to the public register, including those acting on behalf of a company. This aims to further enhance the accuracy and transparency of information provided to Companies House.
Since 18 March 2025, businesses have been able to register as ACSPs. Such registration is currently necessary only for businesses which plan to verify the identity of clients for Companies House. From no earlier than November 2026, businesses will need to be registered as an ACSP to be able to file on behalf of clients.
ACSPs are agents, such as accountants or solicitors, that have registered with Companies House to file or complete other activities on behalf of clients. To become an ACSP, agents must have a UK registered address and be supervised by a UK Anti-Money Laundering (AML) supervisory body. Members should consider their supervisory body and status of its registered address in order to become an ACSP.
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.
Since the roll out of identity verification and the ACSP regime an issue has emerged for Chartered Accountants Ireland member firms which are not AML supervised in the UK and do not have a UK registered address. Such members or businesses would typically be supervised for AML purposes in Ireland, not the UK, but may have clients for whom they need to file with Companies House. 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, and the Institute continues to advocate for change.
Please also see recent article by the Institute on UK Authorised Corporate Service Providers (ACSPs) -Tips and pointers for practice.
Companies House progress report
In June 2025, Companies House issued its second progress report on the implementation of the changes brought in by the ECCTA. It is committed to becoming an active gatekeeper and the report gives examples of how it is actively tacking economic crime, refining register data and strengthening collaboration with several law enforcement agencies to establish a united front against economic crime.
Changes to be introduced in the future
There are other large and complex changes that will be introduced in phases over the coming years, and some of these changes require secondary legislation. Some of these changes are outlined below with more detail included in the transition plan available on Gov.uk.
By no earlier than November 2026
Companies House should be able to:
By the end of 2026
Companies House should be able to:
Failure to prevent fraud offence
We draw attention to the inception of the “failure to prevent fraud” (FTPF) offence which came 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 and the page containing the guidance has been updated since. The page notes that while legislation is binding, this guidance is advisory. Moreover, the guidance is not a substitute for reading the legislation or obtaining professional legal advice.
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 see our webpage on Company law thresholds – United Kingdom. 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 be transitioning towards filing accounts by software only in due course. 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 to streamline 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.
Other resources
Since the phasing in of ECCTA instead, 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.
Frequently asked questions - Register as an Authorised Corporate Service Provider (ACSP)
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: 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: What happens when an individual’s name is different on the register to their ID?
Answer: An individual can continue to use the name they wish to be known by, even if this is different from the name on their identity documents. Companies House will ask for a reason why the name is different. When an individual successfully verifies their identity, they will be provided with a personal code. This code is used to link their identity to their role.
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 are able to voluntarily verify their identity from 8 April and this became a legal requirement from November 2025.
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.
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. Identity verification is compulsory for new directors and people with significant control (PSCs), existing directors and PSCs and anyone acting on behalf of a company.
Question: What are the enforcement policies available to Companies House?
Answer: Companies House have been given the power to impose financial penalties for most of the offences under the Companies Act and where a financial penalty is deemed appropriate. They can be used as an alternative to prosecution. More information is available here.
These pages are provided as resources and information only and nothing in these pages purports to provide professional or legal 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.
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