When an accounting or formation practice needs ACSP registration

Accounting firms and company formation practices now need to separate two questions that are easy to blur together: are you verifying someone's identity for Companies House, or are you only helping with filings and company admin? That distinction matters because it changes whether ACSP registration is needed now, what compliance work sits behind the service, and what your team should be promising clients.

At the moment, Companies House requires agents to register before they verify a client's identity for Companies House. By contrast, agents that only file for clients are on a different timetable: wider agent registration is a future requirement, and the authorised-agent filing service will be available no earlier than November 2026.

For accounting and formation practices, the decision is therefore partly regulatory and partly operational. Before you apply, it is worth checking AML supervision, who in the business can register, how identity checks would actually be carried out, and whether your onboarding documents and engagement terms match the service model you want to offer.

This article is general information only and is not legal advice.

The service you offer determines the route

Three common service models lead to different decisions:

• Sole practitioner who wants to verify directors or PSCs for clients: you can apply in your own name, but you must already be supervised by a UK anti-money laundering supervisory body and be ready to run the full Companies House identity-check process.
• Accounting practice that wants to add identity verification as a client service: register before you start verifying. A senior person in the business must apply, and Companies House will also consider whether the applicant meets the fit and proper criteria for ACSPs.
• Formation agency that currently files for clients but does not verify identities: do not assume you must register immediately just because you file. If you are not planning to verify identities now, the immediate trigger is not there, although future authorised-agent filing requirements are coming.

For many practices, the real decision is commercial as well as regulatory. ACSP status is not just another online account. It creates an authorised-agent verification workflow, record-keeping duties and compliance risk if checks are not done to the required standard.

What you need before you apply

ACSP registration sits on top of anti-money laundering supervision. It does not replace it.

Under Companies House's application guidance, the agent must already be supervised by at least one UK AML supervisory body. Companies House registration does not give you AML supervision, and not every business is eligible for that supervision in the first place. If your practice is still sorting out its AML status, that needs to be dealt with before ACSP registration.

The application also has to come from the right person. Sole traders can register themselves. For other businesses, the applicant needs a senior role such as director, general partner, partner or member, depending on the structure.

Before applying, check that your practice details match across your records. Companies House checks the AML supervisory body information against the business details you submit. If the AML registration is in a different business name, update that before applying.

You should also expect an identity step for the applicant. The senior person applying must verify their own identity for Companies House before using the registration service, unless that identity has already been verified and Companies House does not require it again.

Finally, remember that AML supervision is only one gate. Companies House makes a separate fit and proper assessment. Having AML supervision does not guarantee approval.

The fit and proper test is separate from AML supervision

Companies House can refuse an application if the applicant is not fit and proper to carry out ACSP functions, and it can continue monitoring that after registration.

The published criteria are not a simple tick-box test. The registrar looks at the circumstances of each case and may consider how serious an issue was, when it happened and whether it has been resolved.

The registrar may consider factors such as:

• relevant insolvency issues or bankruptcy
• director disqualification, criminal convictions, or regulatory or disciplinary findings
• serious or repeated failures to meet Companies House obligations
• false or misleading filings, failure to respond to queries, or other conduct raising concerns about honesty, integrity, reliability or competence

That matters for practice owners because ACSP status is not something to treat as an admin add-on. If your filing history, internal controls or governance are untidy, fix those issues before you apply rather than assuming AML membership alone will carry you through.

What acting as an ACSP actually involves

The biggest operational change is Companies House identity verification. If your practice verifies someone for Companies House, you must meet the Companies House identity verification standard in full.

That means completing every required step, not just collecting a passport copy and proof of address because that feels familiar from wider onboarding. The standard requires the ACSP to ask for specified information about the person, obtain documentary evidence, validate documents through the permitted route, and keep the necessary records. The authoritative document lists and route-specific requirements sit in the Companies House standard itself, so your team should use that as the working document.

Checks can be done remotely or in person. You can also use a commercial identity platform. But outsourcing the mechanics does not outsource responsibility. Your practice still has to be satisfied that every required step has been completed and be able to explain why the process used was appropriate. If the platform only covers part of the standard, your practice must complete the rest.

There is also a records duty. If you verify someone's identity for Companies House, you must keep records of those checks for seven years. That includes copies of the documents used and the information needed to evidence the verification.

A useful way to think about ACSP work is that it creates a separate Companies House compliance workflow inside your firm. It needs trained staff, a defined review process, secure retention, and a clear decision on who is allowed to sign off a verification.

How this changes your client process and paperwork

If you offer ACSP verification, your client onboarding terms for UK accounting firms should say so clearly. This is not because a contract replaces the legal rules, but because your documents should match the service you are actually providing.

In practice, your accountant terms of engagement package should cover:

• whether you are verifying identity for Companies House or the client will verify directly
• what information and documents the client must provide
• how the process will be carried out, including whether a third-party platform is used
• fees and when they are payable
• timing assumptions and what happens if information is incomplete or inconsistent
• the limits of the service, including that verification does not replace broader legal, tax or regulatory advice
• who will make the relevant Companies House filing after verification

Your internal procedures should also spell out who requests documents, who reviews them, when an escalation is required, where records are stored, and who is responsible for the seven-year retention period.

Without those documents, accounting firms often end up with uncertainty over scope, missed handoffs between onboarding and filing teams, and weak evidence if Companies House later asks questions.

Ongoing duties after registration

Registration is not the end of the job.

Companies House says an authorised agent must tell it about changes to the registered details it holds within 14 days. If your correspondence address, email address or other registered information changes, your update process needs to catch that quickly.

You will also have an authorised agent account. The account can have additional users, but colleagues should use their own login access rather than shared credentials. In practice, that means deciding which team members need access and who controls user permissions.

There is real enforcement risk if the firm does not comply. Companies House may ask for more information about filings, identity checks or compliance. It can suspend or cease an agent's status, which can stop the business from acting as an authorised agent. Suspension can block account users from accessing ACSP services. Cessation stops the practice verifying identities for Companies House and, once the authorised-agent filing service is live, filing on clients' behalf in that capacity.

Those consequences are not just technical. They can interrupt client work, force repeat checks for people whose identities were verified through the agent, and create a reputational problem if clients suddenly cannot complete filings through your practice.

One practical example: accountant verification or director self-verification?

Imagine a client asks your firm to help appoint a new director and sort out identity verification.

One option is for the director to verify directly through GOV.UK One Login using the existing individual route. That may suit a client who is comfortable handling the step personally and does not need your practice to take on verification.

The other option is for your AML-supervised practice, if registered as an ACSP, to verify that person for Companies House. If you do that, you take on an authorised-agent verification workflow with its own standard, records duty and compliance exposure. You are not just helping the client upload a document. You are taking responsibility for meeting the Companies House verification standard and being able to evidence that process later if asked.

For some practices, that service will be worth offering because it keeps the corporate administration process in one place. For others, it may be better to let clients use the direct route unless there is a good operational reason for the firm to take on verification work.

The practical difference is often about scale and control. A firm that already has disciplined onboarding, secure document handling and clear reviewer sign-off may decide ACSP verification fits naturally into its service model. A smaller practice that only occasionally helps with Companies House changes may decide that director self-verification is simpler and lower risk.

Either approach can be sensible if the engagement terms are clear. What matters is that your team does not drift into verification work informally. If staff are collecting identity evidence and telling clients that the firm will verify them for Companies House, the practice needs to be sure it has the right status, the right process and the right records behind that promise.

Key Takeaways

• ACSP registration is currently needed if your practice plans to verify clients' identities for Companies House.
• If you only file for clients and are not verifying identities, the immediate registration trigger is different, although wider agent registration and authorised-agent filing are still future changes.
• You must already have UK AML supervision before applying, and the application must be made by an eligible senior person.
• Companies House applies a separate fit and proper test, so AML supervision alone does not guarantee registration.
• If you act as an ACSP, you need a compliant verification workflow, seven-year record keeping, user-access controls and a process to update Companies House within 14 days if details change.

If your practice is weighing up ACSP registration, Sprintlaw UK's legal team can help with the practical documents around that decision, including engagement terms, client onboarding wording, verification process clauses and related commercial contracts. To discuss your options, call 08081347754 or email team@sprintlaw.co.uk.