What is an Authorised Corporate Service Provider (ACSP)?

An Authorised Corporate Service Provider (ACSP) is a business that is covered by UK Money Laundering Regulations and has approval to act as an intermediary between registrable entities and Companies House.

Many individuals and organisations, such as accountants and company formation agents, already perform the functions of an ACSP. However, under new legislation, they will soon be required to register as Authorised Corporate Service Providers if they wish to continue doing so. 

In this post, we explain what ACSPs do, the types of businesses that will be able to register as ACSPs, and the process of applying to become an Authorised Corporate Service Provider.

The role of Authorised Corporate Service Providers

The term ‘Authorised Corporate Service Provider’ (ACSP) was introduced by the Economic Crime and Corporate Transparency Act 2023 (ECCTA). In the near future, all intermediaries and third-party agents who file on behalf of companies and other registrable entities will have to register as ACSPs.

Upon doing so, the Authorised Corporate Service Provider will be able to carry out official identity verification checks on individuals affiliated with registrable entities and submit information to Companies House (the Registrar) on behalf of clients. 

Identity verification checks

Individuals who incorporate or control companies in the UK or file information with Companies House will soon be required to verify their identity under a new system. They will be able to do this directly with Companies House or through an Authorised Corporate Service Provider.

The identity verification process will apply to new and existing:

• company directors
• company secretaries
• people with significant control (PSCs)
• members of limited liability partnerships
• general partners of limited partnerships
• anyone else who submits filings at Companies House on their own or another’s behalf 

The new ID verification checks aim to increase corporate transparency in the UK, reduce fraudulent appointments, and improve the accuracy of information on the Companies House register.

Whilst agents are already required to perform due diligence checks on clients under the UK Money Laundering Regulations, the new identity verification process will be more stringent. 

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The individual subject to the check will have to present a primary identity document (e.g. a passport or driving licence) and take a photograph of their face. The two will then be compared electronically using likeness-matching technology.

If the check is successful, the person will be notified in a matter of minutes and obtain a verified status. This should be a one-off requirement. However, in certain situations, re-verification may be necessary. For example, if a person changes their name or the Registrar suspects fraud.

Whether an individual verifies directly with Companies House or through an Authorised Corporate Service Provider, the ID checks will achieve the same level of assurance of the person’s claimed identity. 

ACSPs will be required to file a statement with Companies House to confirm that an identity check meets the necessary standard. They must also retain identify verification records for inspection by the Registrar.

Submitting information to Companies House on behalf of clients

Many individuals and organisations, such as company formation agents and accountants, are responsible for filing information with Companies House on behalf of their clients. These filings include:

• applications to register a company  
• confirmation statements 
• annual accounts 
• notifications of changes to company details (e.g. change of registered office address, appointment or removal of a director, change of details for an existing director or PSC) 

When the requirement to register as an ACSP comes into force, intermediaries and third-party agents will need to apply to become an ACSP if they intend to continue submitting such information to the Registrar on behalf of their clients. 

By registering as an Authorised Corporate Service Provider, Companies House will be able to confidently identify those who are making filings and acting on behalf of companies and other registrable entities. This will make it easier to uncover and take action against agents who fail to act with a lawful purpose.

Who can register as an Authorised Corporate Service Provider?

Any individual, business, or organisation can register as an Authorised Corporate Service Provider if they are subject to supervision by one of the Anti-Money Laundering supervisory bodies in the UK, such as:

• HM Revenue & Customs (HMRC) 
• Financial Conduct Authority
• Association of Chartered Certified Accountants (ACCA)

The types of businesses likely to register as ACSPs are those who already submit information to Companies House on behalf of clients, including:

• company formation agents such as 1st Formations
• company secretarial service providers 
• solicitors and other independent legal professionals
• accountants, tax advisers, auditors, and insolvency practitioners
• professional trustees
• software providers that facilitate the submission of information at Companies House through their software services
• businesses providing professional address and mail-forwarding services (e.g. registered office and service addresses) to customers that are companies, partnerships, or similar legal persons  
• any individual or company providing services as a nominee director, nominee company secretary, nominee shareholder, or similar
• any individual or company providing their services as a company director, company secretary, or partner to another company (unless the other company is a member of the same group)
• virtual office service providers
• estate and lettings agency businesses

When the new measures come into force, all such intermediaries and agents will need to apply to register their business as an ACSP before they can continue filing information on behalf of their clients.

How to register as an Authorised Corporate Service Provider

The new registration service for Authorised Corporate Service Providers is not yet available. Companies House will announce in due course when the service launches.  When this happens, a senior person in the business (e.g. the sole trader or a company director) must complete the process to register the business as an ACSP. 

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This will involve providing information about the business, including its Anti-Money Laundering supervisory body membership number. The individual making the application will also have to complete identity verification.

Once registered, the ACSP will receive a new digital account and unique identity number. This will allow the ACSP to complete identity verification checks and file information for their clients, whilst also enabling Companies House to identify that the information they receive is from an authorised source.

The person responsible for registering the business as an ACSP must keep the registration details up to date at Companies House. They will also be able to add other people who work for the ACSP to the digital account. 

These additional individuals won’t be subject to identity verification checks. Nevertheless, they will have the authority to perform authorised activities on behalf of the ACSP, such as carrying out identity checks and filing information for clients.

Thanks for reading

If you’re an intermediary or agent who intends to register as an Authorised Corporate Service Provider, you don’t need to do anything at the present time. Companies House will announce in due course when the new measures come into force.

When this happens, we will provide an update in the 1st Formations Blog and contact any clients who will be affected by the changes. You can also sign up for Companies House email newsletters to keep up to date with important news and changes to UK company law.