The Economic Crime and Corporate Transparency Act 2023 (ECCTA) is transforming Companies House from a passive information repository to an active regulator with enforcement powers. 

As part of the reforms, new rules require compulsory identity verification for directors, persons with significant control (PSCs) and those filing information at Companies House, such as accountants.

Accountants acting as authorised corporate service providers (ACSP) need to be aware of the changes and their implications for clients. But overall, the ECCTA represents a significant step towards boosting transparency and combating economic crime within the UK corporate sector. 

To ensure accountants who wish to act as ACSPs are up-to-date, ICAEW is hosting a free webinar with Companies House to explain the requirements and the risks of providing authorised corporate services.

Firms can now register with Companies House as ACSPs following the opening of the Companies House ACSP registration process.

The webinar will explain the latest requirements, the risks of providing these services and how they impact your firm and clients. All members can register for the 11 June webinar. To boot, attendance at this webinar will contribute up to one hour of verifiable CPD, providing members can demonstrate that the content is relevant to their role.

ICAEW’s anti-money laundering supervisory team and Companies House will present:

• an overview of the ECCTA; 
• guidance on ACSP registrations; and 
• direction on the identity and verification checks required for directors and people of significant control.

Speakers will include Mark Buckley, Senior Implementation Lead, Companies House, Michelle Giddings, Head of AML and Operations, ICAEW, and Sandy Price, AML Manager, ICAEW.

Companies House’s Mark Buckley will provide members with a detailed walk-through of the ACSP registration process, as well as the ‘Tell Companies House you have verified someone’s identity’ service.

The first set of changes under ECCTA were introduced on 4 March 2024. These include:

• greater powers to query, remove and refuse information, including the ability to investigate and enforce; 
• stronger checks on company names; as well as 
• new rules for registered office addresses, among others.

How to register as an ACSP

“The webinar will outline who needs to register initially, and what services you would provide that would require you to register now if you’re verifying your clients at Companies House. If you’re offering a verification service, our firms would need to register now, otherwise there’s no huge rush,” says Sandy Price, AML Manager at ICAEW.

One of the issues that is slowing down firms in their registration process with Companies House is knowing their AML supervisor’s registration number. For ICAEW firms, that’s their firm number with ICAEW so when they register, they need to know their C00 number, which is how ICAEW recognises them, explains Price.

The webinar will be a prime opportunity for member firms to ask questions directly of Companies House during the Q&A session after the webinar. Moreover, if a specific question can’t be answered on the day, ICAEW will find the answer, and respond after the session.

Managing AML risks

This is another core point for members, Michelle Giddings, Head of AML and Operations at ICAEW, says. “One of the things that we’re also going to cover is the AML risk associated with ACSP. There’s a complexity. To be an ACSP, you have to be AML supervised. But the AML regulations themselves do not cover ACSP work.” 

So, when ICAEW’s AML team does an inspection of a firm, technically, if they have an ACSP file or an ACSP-style client, that’s not in ICAEW’s remit to look at for AML supervision, but “nonetheless, we think firms should be alive to the AML risk of providing this particular service”, Giddings says.

The whole purpose of the ACSP system is to have tighter control and knowledge and verify either who the filer is or the ACSPs are, but also to make the data at Companies House more reliable and more accurate, somebody having signed it off to say that it’s okay.

For many firms, Giddings says, this will be a straightforward process for their existing clients, because firms are familiar with their clients. They will understand the amount of risk within those clients, either filing on their behalf or signing off that this person is who they say they are, within the rules of what you have to do for ACSP verification. 

However, Giddings warns: “Firms do need to be alive to the risk of people walking into their offices who need to be verified but want to hide who they are or are not being honest about who they are.”

There are, of course, very strict procedures around how firms must verify. “Our firms would need to know they can use the process called ID Validation Technology to verify the passport and/or driving licence are legitimate,” says Price. “Or they can verify the individual themselves, but if they do that, firms will have to have a number of documents and keep records for seven years.”

Firms that do it themselves will also have to employ a professional who is trained in identifying falsified documents to Home Office standards. If firms fail to comply, Companies House can remove you from the ACSP register, which means you will not be able to provide that service to your clients.

“The repercussions of not verifying appropriately really have a significant impact on the firm’s ability to provide a service to all their clients,” Price says.

If Companies House removes an ACSP from the register, all of your clients have to get themselves re-verified, so clients will know. “There’s reputational damage to doing the wrong thing. And it’s Companies House that polices all of that, not ICAEW,” Giddings says.

With the need for professional scepticism drilled into accountants throughout their years of training and education, accountants are well placed to provide these critical services to their clients and develop more service lines in their area, but there are risks to carefully consider first.