Companies House ID verification and the ACSP regime
Two deadlines, one of which stops you filing for clients and the other of which stops your clients existing properly. Neither is hard. Both need somebody to own them, and in most practices nobody does.
From spring 2026, a Companies House filing can only be made by a verified officer or employee of the company itself, or by an Authorised Corporate Service Provider — so a practice that files for clients must be registered as an ACSP or it loses the ability to file. Separately, every existing director and PSC must verify their identity by 18 November 2026. The practice work is not the registration, which takes an afternoon; it is verifying several hundred clients who will not do it until somebody makes them.
The two things, which keep getting confused
These are separate obligations with separate deadlines, and conflating them is how practices end up doing the easy one and missing the expensive one.
| Obligation | Who it lands on | When |
|---|---|---|
| Register as an ACSP to file for clients | Your practice | Spring 2026 |
| Verify identity as a director or PSC | Every client individually | 18 November 2026 |
Identity verification has already been compulsory since 18 November 2025 for new director appointments and new PSC registrations. What arrives in 2026 is the back catalogue: every existing director and PSC, all of whom have been able to ignore it so far.
The ACSP registration is the small job
To register as an Authorised Corporate Service Provider your practice needs to be supervised for anti-money-laundering purposes — which, if you are licensed by a professional body or registered with HMRC, you already are — and the individuals doing the filing need to have verified their own identity.
It is an afternoon of work. Do it early rather than in spring, for one unglamorous reason: when a deadline arrives, everybody who left it late arrives at the same portal on the same fortnight. The cost of doing this in January is an afternoon. The cost of doing it in April is an afternoon plus whatever the queue is, while clients are asking why their confirmation statement has not gone in.
The consequence of not doing it is absolute rather than financial. It is not a penalty; it is that you can no longer file at Companies House for your clients. For most practices that is a service they have provided without thinking about it for twenty years.
Client verification is the real work, and it is not really a compliance job
Several hundred directors and PSCs, each of whom has to complete an identity check they did not ask for, do not understand, and have no personal deadline pressure about until something is refused.
There are two routes. The client verifies themselves through GOV.UK One Login, which is free and takes most people about ten minutes. Or you verify them, as their ACSP, which is more work for you and more certain.
The decision worth making deliberately is which of those you offer, to whom, and whether it is chargeable — because the default, which is to send everybody a link and then chase the ones who ignore it, is the most expensive option and the one most practices will drift into.
A workable split: send the self-service route to everyone with a clear deadline and a single reminder, and reserve doing it for them for the clients where a rejected filing would genuinely hurt — the ones with a confirmation statement or accounts falling due in the weeks after the deadline. That is a list you can produce from your own deadline tracker today, and it is usually a much smaller number than the total.
Why this is a workflow problem in disguise
Nothing here is technically difficult. The difficulty is that it is a one-off task, spread across several hundred people, with a hard date, sitting on top of a January and an April that were already full.
That is exactly the shape of work that founder-led practices handle badly — not because anyone is incapable, but because a one-off with no owner defaults to whoever notices, and whoever notices is usually the owner. It ends up in an inbox, done in evenings, tracked in a spreadsheet nobody else can see.
The fix is dull and it works: one named owner, one list, one status field on the client record, and a weekly number reported at the same meeting as everything else. A practice that already runs a weekly operating review absorbs this without noticing. A practice that does not will feel it as three months of low-grade background stress.
What it collides with
The 18 November 2026 deadline sits in the same year as the first MTD for Income Tax quarterly updates, which start 7 August 2026. So the autumn of 2026 contains a new quarterly filing cycle bedding in, a hard identity-verification deadline for your whole company client base, and then January.
Taken one at a time, each is manageable. Taken together, with no plan, they are the reason 2026 is the year a lot of practices discover that their operations were being held together by the owner working late.
The five-step version
- Register the practice as an ACSP now, and get the individuals who file verified at the same time. Afternoon's work, removes the binary risk.
- Produce the list. Every director and PSC across your company clients, with a verified/not-verified flag on the client record. Not a spreadsheet — a field, so it can be reported.
- Decide the policy. Who gets the self-service link, who you verify directly, and whether the second one is chargeable. Write it down in three lines so the team applies it without asking.
- Prioritise by filing date, not alphabetically. Clients with accounts or a confirmation statement due between November 2026 and February 2027 go first, because those are the ones where an unverified director turns into a rejected filing.
- Report the number weekly from September. Percentage verified, by owner. It is the only thing that turns a deadline into progress.
The opportunity, such as it is
It is not a big one, but it is real. Every client is going to receive confusing correspondence about this from Companies House, and most of them will not act on it. A practice that gets ahead — a clear email in plain English, a deadline, and an offer to handle it — looks organised at precisely the moment its competitors look silent.
That is worth more than the fee. The clients most likely to move firms are the ones who felt unattended during something they did not understand.
Common questions
What exactly changes in spring 2026?
The population of people who can file at Companies House on behalf of a company narrows. A filing must come from a verified officer or employee of the company itself, or from a registered Authorised Corporate Service Provider or its verified people. In practice that means a practice which files for clients must be registered as an ACSP or it simply loses the ability to file for them — it is a capability question rather than a penalty.
Who has to verify their identity, and by when?
Every director and every person with significant control. It has already been compulsory since 18 November 2025 for new appointments and new PSC registrations; existing directors and PSCs have until 18 November 2026. Missing it can mean filings rejected, appointments blocked and enforcement action, so the risk sits with the client but the chasing sits with you.
Do we have to become an ACSP?
Only if you want to keep filing on clients' behalf. If you do, you need to be supervised for anti-money-laundering purposes — which you already are if you are professionally licensed or HMRC-registered — and the people doing the filing need to have verified their own identity. The registration itself is straightforward; the reason to do it early is to avoid the queue rather than the difficulty.
Is ID verification the same as our AML client due diligence?
No, and assuming it is has caught firms out. They are separate regimes with separate evidence requirements, and completing one does not satisfy the other. A client you have known and AML-checked for fifteen years still has to verify with Companies House.
Can we charge for doing it?
You can, and whether you should is a positioning decision rather than a pricing one. The defensible version is to make the free self-service route genuinely easy for everyone, and charge only where you are doing the verification for them as a service. What is hard to defend is charging for something the client could have done themselves in ten minutes had anyone explained it clearly.
What happens if a client simply will not do it?
Their filings start being refused and enforcement becomes possible. Your exposure is reputational rather than legal — the obligation is theirs — but a director whose accounts are rejected will not remember that distinction. Evidence that you told them, in writing, with a deadline, is worth having, which is another reason to run this from a client-record field rather than an inbox.
Where does your firm actually stand?
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