ACSP Verification: Compliance Is Not a Numbers Game

337 Businesses/ACSPs were Penalised in Less Than A Year
Since the implementation of the ECCTA/ACSP rules on 18 November 2025, 337 businesses and ACSPs have reportedly been penalised, with penalties published by HMRC, in less than a year after ECCTA identity verification began.
The right question to ask is: Is your accountant reliable and compliant?
HMRC's published enforcement records contain 337 entries, including anonymised penalty records, relating to businesses that failed to comply with the Money Laundering Regulations. These records highlight why businesses should take their accountant's compliance standards seriously.
Why getting identity verification right matters for businesses, directors, beneficial owners and the integrity of the UK companies register.
Not Every ACSP Is the Same: Is Your Accountant Compliant and Reliable?
Choosing an Authorised Corporate Service Provider (ACSP) is not simply about completing an identity check quickly. It is about choosing a provider that understands its responsibilities, follows the applicable standards and takes the protection of clients and the integrity of the UK companies register seriously.
HMRC publishes official records of businesses that have not complied with the Money Laundering Regulations, including penalty notices issued to accountancy service providers and other regulated businesses. These records illustrate the financial consequences that can follow failures to meet applicable AML obligations.
Rather than reproducing individual names, we encourage businesses to consult HMRC's published enforcement records and understand the importance of effective compliance. See it yourselves how serious things can be: https://www.gov.uk/government/publications/businesses-not-complying-with-money-laundering-regulations/businesses-that-have-not-complied-with-the-money-laundering-regulations-2025-to-2026
Companies House also publishes information about ACSPs whose status has been suspended or removed. These records must be interpreted carefully: suspension or removal does not automatically establish misconduct, and AML registration penalties are not necessarily findings of identity-verification failures.
The wider lesson is clear. ACSP services should not be judged on speed or convenience alone. The quality of the process, the evidence obtained, the provider's understanding of its obligations and its commitment to client protection all matter.
Companies House Is Also Scrutinising ACSPs
Under the Economic Crime and Corporate Transparency Act 2023 (ECCTA), Companies House has introduced identity verification requirements intended to improve the reliability of information on the UK companies register and make it harder for companies to be misused for economic crime.
Companies House maintains a register of Authorised Corporate Service Providers whose status has been suspended or removed. Its published guidance explains that suspension may occur while Companies House investigates or requests further information about an ACSP's business, AML supervision, filings or identity verification processes.
An ACSP's status may also be removed in other circumstances, including where the provider no longer wishes to remain registered or does not comply with applicable legal requirements. Suspension or removal should not automatically be interpreted as proof of misconduct. Nevertheless, the register demonstrates that ACSP status is subject to ongoing scrutiny.
For businesses choosing a provider, this reinforces the importance of looking beyond registration status alone and considering the quality of the provider's processes and its approach to compliance.
What Happens If the Wrong Person Is Verified?
Identity verification is not simply another step in a company filing. It helps protect businesses, directors, people with significant control (PSCs) and ultimate beneficial owners (UBOs).
If the wrong person is verified, an unauthorised individual could potentially attempt to make changes to company records, including director appointments or information relating to ownership and control. The consequences could extend beyond the immediate filing, affecting the company, its owners and those who rely on the accuracy of the public register.
The critical question is therefore not simply whether a check has been completed. It is whether the correct individual has been verified using an appropriate method, with sufficient evidence and in accordance with the applicable legal standard.
Companies House sets out the requirements that ACSPs must follow in its official guidance, How to meet the identity verification standard.
These requirements should guide the verification process, rather than convenience or speed alone.
Identity Verification Is Not the Whole of AML Compliance
A genuine identity document does not, by itself, establish that every relevant risk has been addressed.
Depending on the engagement and applicable legal requirements, AML due diligence may also involve understanding the client, identifying beneficial ownership, assessing risk, considering sanctions exposure and politically exposed person (PEP) risks, and undertaking appropriate ongoing monitoring.
Companies House identity verification and AML customer due diligence serve related but distinct purposes. Completing one does not automatically satisfy the other.
Businesses should understand the difference and ensure that the processes appropriate to their circumstances are in place. HMRC's guidance on AML registration for accountancy service providers explains when accountancy service providers need to register for AML supervision.
Our Principle as an ACSP: Compliance and Client Protection Come First
As a UK accountancy practice and ACSP, our approach is straightforward: compliance comes first.
We aim to undertake identity verification carefully, follow the applicable requirements and maintain appropriate evidence and records. We do not accept an engagement where we cannot obtain sufficient evidence or achieve the required standard.
For us, this is not about processing the highest possible number of applications. It is about protecting our clients, respecting the responsibilities attached to ACSP status and helping preserve the integrity of the UK companies register.
Every verification concerns a real person, a real business and potentially significant ownership interests. That responsibility deserves appropriate checks, sound judgement, sufficient evidence and proper record keeping.
ECCTA is intended to strengthen the integrity of the UK companies register and help prevent companies from being misused for economic crime. Achieving that objective depends not only on legislation, but also on the quality of identity verification in practice.
When choosing an ACSP, businesses should therefore look beyond speed and convenience. They should have confidence in the provider's processes, understanding and commitment to meeting the required standards.
Need a reliable ACSP? Our Expert in Elaga Accountancy can help, discuss with us now on how we approach identity verification and compliance.
Official Sources
HMRC, Businesses that have not complied with the Money Laundering Regulations (2025 to 2026)
Companies House, Ceased or suspended Authorised Corporate Service Providers (ACSPs)
Companies House, How to meet the identity verification standard
HMRC, Money laundering regulations: accountancy service provider registration
Contains public sector information licensed under the Open Government Licence v3.0, except where otherwise stated.
What Does ECCT Act Means For You Now ?
The ECCT Act is a critical step towards improving the transparency and accountability of businesses in the UK. While it introduces new challenges, it also offers opportunities for companies to strengthen their operations and protect themselves from legal and financial risks. As these rules are being phased in, it is crucial that businesses, especially those operating at the company level, stay proactive in understanding and complying with these changes. Always consult your accountant , we at Elaga Accountancy can ensure that you are properly prepared and protected in the face of these evolving legal requirements.
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