Later this year, the government is bringing in changes from the Economic Crime and Corporate Transparency Act (2023), this act aims strengthen identity checks to reduce fraud and deter those who wish to use companies for illegal purposes. Anyone submitting to Companies House as a director, PSC (Person significant control), or agent will have to verify their identity biometrically before submitting to Companies House.


Dates of implementation

  • Optional registration Date 18th March 2025
  • Mandatory registration is in autumn 2025 (The precise date has not been released yet)


Please note that this mandatory sign up date is for incorporations and appointments subsequent to the mandatory registration date. There is a 12 month transition period for companies which existed before the mandatory sign up date of Autumn 2025.

 

Implications for Accountants 

Accountants will have to register as ACSPs (Authorised Corporate Service Provider). Becoming an ACSP validates your AML supervised status, this means the accountant will have permission to submit and validate the identity of the directors and PSCs of a company for these biometric checks (See appendix 1 to see what counts as a valid biometric check).

Requirements and process to become an ACSP:

  • They must be supervised by one of the 25 AML supervisory bodies. Companies house will check with this supervisory body to ensure they have the correct credentials to complete AML checks.
  •  The accountant can register directly with companies’ house, they must pay £55 to become an ACSP.
  • They will be asked to verify their own identity biometrically with a passport or valid form of biometric identification.
  • After this, they will be given a unique account and login where they can complete and log checks.


Accountant completing checks after registering as an ACSP

Once the accountant becomes a ACSP they must complete biometric checks when acting as an agent of their clients and submitting to company’s house. (See appendix 2 for the requirements of an ACSP by companies house)

An ACSP will be able to validate the identity of their clients two different ways:

  1. On Companies house
  2. A software provider such as Capium


If an ACSP verifies the client’s identity on software, they must:

- Notify company’s house with:

  • The person’s details
  • Which documents you used to verify their identity
  • Give details from the identity documents
  • confirm you have completed checks to verify their identity to the required standard
  •  They must keep the Verified document for 7 years.

Please note:

  • The accountant will not have to directly submit the verification to Companies House, however, they must keep the records on file and if companies house asks for proof of verification, the accountant must provide it.
  • If the accountant does not complete these checks, they may face criminal or civil penalties.


How Capium Can help!

These checks are currently not in Capium, however, once the regulation is introduced and enforced, Capium will release tools within the ecosystem where you can complete these checks. The tools will be:

  1. MyAdmin and Practice Management – These checks will be £2.50 + VAT per check. This is on a pay as you go basis, not on a subscription model.
  2. Company Secretarial module - There will also be the biometric checks within the company secretary module.


Once the ACSP verifies the identity of the client, they would then have to declare on Companies house that they verified the client’s data under penalty.



 

Appendix 1 – Documents that can be used are 1 from Group A or 1 from Group B tp validate a client’s identity

Group A

•         a passport or Irish passport card – these can be up to 18 months expired

•         an identity card with biometric information from the EU, Norway, Iceland or Liechtenstein

•         a UK biometric residence permit (BRP) – these can be up to 18 months expired

•         a UK biometric residence card (BRC)

•         a UK accredited PASS card

•         a UK or EU driver digital tachograph card

•         a UK, Channel Islands, Isle of Man and EU photocard driving licence (full or provisional)

•         a UK HM Forces ID Card

•         a UK HM Armed Forces Veteran Card

•         a UK Frontier Worker permit

•         a photographic work permit (government issued)

•         a photographic immigration document

•         a photographic visa

•         a UK, Channel Islands and Isle of Man firearms licence

•         another type of photographic ID listed on PRADO - such as a National Identity Card (Pakistan), crew member certificate (South Africa), or Permanent Resident Card (USA)

Group B

•         birth or adoption certificate

•         marriage or civil partnership certificate

•         non-photographic immigration document

•         non-photographic visa

•         non-photographic work permit

•         bank or building society statement

•         UK local authority or social housing rental agreement – this must be for the person’s current address

•         mortgage statement – this must be for the person’s current address

•         UK council tax statement – this must be for the person’s current address

•         utility bill – this must be for the person’s current address

 

Appendix 2- Your responsibilities as an authorised agent

Companies House authorised agents, also known as Authorised Corporate Service Providers (ACSPs), must comply with the following legal responsibilities.

  1. The business must always be registered with at least one Anti-Money Laundering (AML) supervisory body.
  2. You, or another account owner, must tell us if there is a change to any of the information you provided in the application to register as an agent. You must do this within 14 days.
  3. If we request it, the business must provide more information:
    • your filings with Companies House
    • about identity checks, if the agent verifies someone’s identity for Companies House
    • to prove the agent is complying with its legal responsibilities
  4. If you verify the identity of clients for Companies House, you must keep records of the checks you carry out. You must keep these for 7 years from the date you complete the checks.

⚠ All officers of the business need to be aware of these responsibilities. If the business does not comply, we could suspend or stop it from acting as an authorised agent. Every officer could receive a fine or face criminal prosecution.

More information on our AML centre can be found in our library below


https://capium.freshdesk.com/support/solutions/categories/9000116723/folders/9000193271