Changes for the year ahead

Becca Blewett explains the Economic Crime and Corporate Transparency Act changes at Companies House.

You may have seen that there are yet more changes incoming at Companies House as part of the Economic Crime and Corporate Transparency Act 2023 (ECCTA) but may not be aware of what these latest changes mean for you as either a: professional advisor, company director, LLP member or person of significant control (PSC) – defined as someone who owns more than 25% of the share capital or has significant influence or control over a company.

A key change is the requirement for company directors, members of LLPs and PSC’s to have their identity verified with Companies House.

No set date has been announced yet, but all companies will be required to have verified the identity of all of the directors, members and PSC’s before the next Companies House filing requirement (see below), starting from Autumn 2025.

If you want to get ahead of the game,
the ID verification can be done now at Companies House, but it is not compulsory until Autumn 2025.

From Autumn 2025, unless the identity has been verified, no submissions will be able to be made to Companies House. For example, accounts and confirmation statements cannot be able to be filed without this ID verification being completed first. This also includes new company formations.

As no confirmation statements will be able to be filed without the ID verification being completed, it is the aim of Companies House to have the ID verification for all companies to be completed by Autumn 2026 (each Company/LLP needing to file a confirmation statement annually).

Failure to comply with the ID verification requirements within the required time frame may constitute an offence and could
result in financial penalties or sanctions, including disqualification from being a company director.

Who can complete the ID verification?

Company directors, members and PSCs can complete the ID verification themselves via the Companies House website. 

Alternatively, identity verification can be verified via an Authorised Corporate Service Provider (ACSP). An ACSP is an agent who is authorised to file documents at Companies House on behalf of the client, an accountant, or a formation agent for example. The ACSP will complete their ID verification and will need to confirm with Companies House that this has been done to the same standard as carried out by Companies House.

What ID verification is required?

The ID verification requirements at Companies House are different to what you may be used to for Anti-money laundering (AML) purposes.

Company directors, members and PSCs completing ID verification themselves via the Companies House website will need to follow the step by step instructions on screen and will require either a passport or photo driving licence along with the need to have a scan or photograph taken of their face (using a mobile phone – for example) in order for Companies House to compare the two using their own software and verify the identity of the person – our understanding that this process takes around 10 minutes if you have all of the required documents to hand.

If an ACSP is going to carry out ID verification, they will either need to use a robust, special ID verification software and have access to the original document, in order to check the documents in line with the standard, as would be carried out by Companies House. Just a copy of the client’s ID on file and standard AML checks will not be sufficient for these purposes.

The alternative for ACSPs would be to manually check ID documents, but they must ensure that the staff carrying out the checks have training from a specialist training provider, such as the Home Office, in order to be able to detect ID forgeries.

Please note that once a person’s ID is verified, it will apply across all companies they are a member, director or PSC of; therefore, they will not need to do this again.

From a future date in 2026 (specific date not yet announced), only ACSPs will be permitted to file documents at Companies House on behalf of their clients, including accounts, confirmation statements and incorporations.  It is therefore thought that most accountants will register as an ACSP.

Companies House will have the power to suspend or revoke an ACSP’s status if they do not meet verification standards.

Conclusion

We (RRL LLP) will be a registered ACSP to enable us to facilitate ID verification on behalf of our clients using robust identification document validation technology (IDVT) software and are currently trialling various IDVT software to comply with this.

We will be issuing further guidance to our clients over the next few months.

RRL
Truro: 01872 276116
Penzance: 01736 339322
post@rrlcornwall.co.uk
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