Are you ready for the major changes to be brought in by the Economic Crime and Transparency Act 2023 (the ECCT Act 2023)?
I have registered as an Authorised Corporate Service Provider (ACSP), to carry out identity verification checks (IDV) on behalf of my clients for Companies House. Company directors have just a few months to start the ID verification process.
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The timeline of changes in 2025-2026:
- From 25 March – Companies House released the facility for individual Directors/Persons with Significant Control (PSC) to voluntarily verify their identity (via ACSPs or directly with Companies House).
- By Autumn 2025 – compulsory IDV will be implemented for all new incorporations and new Directors/PSCs, and also a 12-month transition phase will commence, which will require more than 7 million existing Directors/PSCs to verify their IDs (IDV to happen as part of the annual Confirmation Statement filing).
- By Spring 2026 – IDV becomes a compulsory part of filing of any document with Companies House (date to be confirmed by Companies House).
- By the end of 2026 – all limited liability partnerships will submit more information, providing greater transparency for users of the register. Completion of the transition period for IDV and commencement of compliance activity against those who have failed to verify.
Directors can verify their ID Via gov.uk ID check app or at a Post Office branch. However, I can help and make the process much easier. We offer two solutions: firstly, an online check which will involve the use of your phone and a website, and 2 minutes of your time. Or secondly a physical meeting with you and your ID, at one of our two locations or at yours.
What are the consequences for failing to carry out identity verification?
Any individual who acts as a director without having had their identity verified, and the company (and its directors) for which they act, will be committing an offence. The validity of any acts carried out by that individual as a director however will not be affected. Directors who act without verification will also be liable to be disqualified. Any person who is not verified will be unable to be appointed as a director for a company seeking to incorporate. It will also be an offence for any person to provide misleading, false or deceptive information without reasonable excuse and there is a new aggravated criminal offence for knowingly providing misleading, false or deceptive information. In both cases this would include any statement made in relation to identity verification.
How easy is it to verify the ID?
With our help, it is very easy. We offer two separate solutions. The first, where it’s not possible to meet with the director, will involve them using their phone and logging onto a secure webpage, with ID to hand. It should just take a couple of minutes, following which we will receive the result, and we can then report to Companies House. The second method would involve a physical meeting with the director to see their ID. We offer facilities at our two locations, or we can come to see you, whichever works best.
What is an ACSP, or Companies House Authorisation Agent?
An authorised corporate service provider (ACSP) is a new requirement designed to help Companies House track who is verifying the identity of individuals involved in companies and filing information on the public register. An ACSP is a type of intermediary between companies and Companies House.
ACSPs will carry out ID checks on directors, PSCs, and those delivering documents to the Registrar on behalf of companies. They are intended to provide the same level of regulatory assurance as direct verification with Companies House.
Have you received special training to enable you to verify the ID and work as an ACSP?
Yes, we have. Jonathan has worked as a qualified solicitor since 1997 and Notary Public since 1999, and so he and his team (which also includes a qualified accountant) have plenty of experience in checking and verifying ID, and dealing with Companies House. In addition, when it comes to handling physical passports and other identity documents, Jonathan and his team have received Home Office approved training which is a requirement.
What happens after you have verified the director’s ID?
We then make an immediate report to Companies House which we do on their portal. This includes certain information about the ID that we have seen, and also their email address. Companies House will then email a unique number to the director, which can then be usedto assist with future filing of documents at Companies House.
What is the deadline for verifying director ID?
The relevant legislation is still passing through Parliament, so the dates haven’t yet been finalised. However, the government states that from a certain date this coming Autumn 2025, when filing the Confirmation Statement, the relevant identity checks must have been made. We are currently in a voluntary period, and we are assisting clients right nowwith the ID checks as it is felt there will be a big rush/bottleneck later this year at CH.
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