On 18 March 2025, Companies House opened registration for Authorised Corporate Service Providers (ACSPs), a key step in the UK’s company law reforms to improve transparency and reduce economic crime. 3CS is now registered as an ACSP and can carry out identity checks for clients.
In this newsletter, we cover what the changes mean for identity verification, including who must be verified, how the process works, and what to do if a person with significant control (PSC) is an organisation. We also explain the new corporate offence of failure to prevent fraud, which will take effect later this year.
Who must complete identity verification?
Under the new rules, identity verification will be required for all company directors (and similar officers), all People with Significant Control (PSCs), and any individual filing documents with Companies House, such as company secretaries or agents. In short, anyone involved in setting up, owning, managing, or submitting filings on behalf of a UK company will need to complete the verification process.
What if a PSC is an organisation?
If a PSC is a corporate entity, it must still meet identity verification requirements through a human representative. This involves selecting one of the organisation’s directors or managing officers to verify their identity on the entity’s behalf. The organisation must confirm the verification within a short timeframe (expected to be 28 days), ensuring all PSCs are traceable to a verified individual.
Timeline and actions to take
The changes will roll out during 2025 and 2026. ACSP registration opened in March 2025, and voluntary identity verification begins in April.
By autumn, checks will become mandatory for new appointments, with a 12-month transition for existing companies. Starting in spring 2026, filing agents must also be verified.
Enforcement is expected by the end of 2026. Acting early can help companies avoid delays or penalties.
How to verify your identity
There are several ways to complete identity verification. You can use the GOV.UK One Login to upload photo ID or answer security questions. In-person checks will also be available at selected Post Offices.
Alternatively, an ACSP can verify your identity and confirm it to Companies House. Once verified, you’ll receive a unique code for future filings. Verification is usually a one-time process unless re-confirmation is required.
New offence: failure to prevent fraud
From 1 September 2025, a new corporate criminal offence called failure to prevent fraud will apply to large organisations. A company can be prosecuted if an employee or associate commits fraud for its benefit and the company did not have reasonable fraud prevention procedures in place.
Crucially, there is no need for senior management to be involved in the fraud for the company to be liable.
Who is affected?
The offence applies only to large organisations meeting at least two of the following thresholds: £36 million in turnover, £18 million in assets, or 250 employees. These thresholds will apply to the whole organisation, including subsidiaries, regardless of where the headquarters or the subsidiaries are located. It should be noted that the offence can apply when fraud took place in the UK, or the gain or loss occurred in the UK, wherever the organisation is based. Small and medium-sized businesses are exempt, though individuals involved in fraud remain prosecutable under existing laws.
How 3CS can help
These changes bring important updates to UK company rules. Identity checks will improve transparency, and larger firms must now take steps to prevent fraud.
Companies should start preparing for verification, while larger organisations should review their anti-fraud measures before the September deadline.
If you need support, feel free to contact our experienced team of commercial solicitors at 3CS.
