ACSP and Anti-Money Laundering Registration for Third Party Providers

ACSP and Anti-Money Laundering Registration for Third Party Providers

The Transition Plan for Companies House provides that by Spring 2025, the Companies House will allow registration for Authorised Corporate Service Providers (ACSP). Accordingly, all third party providers will need to register their business as Authorised Service Providers Further, Anti-Money Laundering Supervisory Registration for Third-Party Providers is also mandated. Let’s examine the same in detail.

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) was enacted with the objective of combatting economic crimes by improving the transparency of companies and other legal entities in UK. It reforms the role of Companies House, an executive agency of the Department of Business and Trade, which is responsible for the incorporation, dissolution, registration, etc of companies in UK. Through this Act, the Companies House has been empowered with significant powers and responsibilities to combat economic crimes.

On 16 October 2024, the Outline Transition Plan for Companies House was released. This plan provides the expected timeframe for implementation of reforms under the ECCTA with respect to the Companies House.

The Transition Plan for Companies House provides that by Spring 2025, the Companies House will allow registration for Authorised Corporate Service Providers (ACSPs)

Let us now discuss the meaning of ACSPs, and who can register as an ACSP.

What is an Authorised Corporate Service Provider (ACSP)?

Authorised Corporate Service Providers (ACSPs) are third-party service providers that have been recognised and authorised by the Companies House to conduct identity verification on behalf of their clients. Under the ECCTA, identity verification can be conducted directly with the Companies House or through an ACSP.

Identity verification is an important component of the reforms introduced through the ECCTA. From Autumn 2025, identity verification of all directors and People with Significant Control (PSCs) of new incorporations will be compulsory. There will also be a transition period of 12 months, in which existing companies would be obligated to conduct identity verification of their directors and PSCs. To conduct identity verification on behalf of clients, entities providing this service must first register themselves as ACSPs.

In essence, ACSPs are third party intermediaries that provide services such as company formation, registration, verifying identity of individuals affiliated with the entity being registered, etc. These include entities such as Trust and Company Service Providers (TCSPs), accountants, solicitors, company formation agents, chartered secretaries, etc. It also includes firms, individuals, agents who are sole traders or part of a company that’s not registered with the Companies House, software providers filing information on behalf of a company or third-party providers.

It should also be noted that third-party agents will be able to register themselves as ACSP from Spring 2026.

Who Can Register as an Authorised Corporate Service Provider (ACSP)?

A Person may apply to register as an Authorised Corporate Service Provider (ACSP) if they meet the following requirements:

  • The Person is a ‘Relevant Person’ as defined under Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017
  • If the Person is an individual and their identity is verified as defined under Section 1110A of the ECCTA
  • If the Person meets any other requirements as implemented by the Secretary of State under any Regulation for the purpose of registration as an ACSP

What Is the Information Required to Register as an Authorised Corporate Service Provider (ACSP)?

The following information is required by an eligible applicant to file an application for registration as an ACSP:

  • The name of the Supervisory Authority that supervises the application under MLR 2017 and the AML Supervisory Body membership number, also called the ID number
  • In cases where a firm is an applicant:
    • The name of the firm
    • The principle office of the firm
    • The firm’s service address
    • The firm’s mail address
    • The legal form of the firm, and the applicable law that governs them
    • The register in which the firm is entered, including the details of the state and registration number of the firm, wherever applicable
  • In cases where the applicant is an individual:
    • The individual’s identity must be verified
    • The individual’s name, including fore name and surname, or title where the individual is usually known by a title
    • Nationality of the individual
    • Birth date of the individual
    • The individual’s service address
    • The individual’s email address
    • The part of the UK where the individual usually resides, or the country or state where the individual resides if that is outside UK

Authorised Corporate Service Providers (ACSPs) Under the ECCTA 2023: Future Steps

For third-party providers that seek to submit information and complete identity verification on behalf of their clients, registering as an ACSP with the Companies House will become a compulsory requirement from Spring 2025. Entities that intend to provide such services to their clients must prepare to register themselves as ACSPs, as well as review and update their identity verification processes to ensure that they are aligned with the reformed requirements under the ECCTA.