This article contains the frequently asked questions in response to our webinar Understanding the ACSP Regime: Latest Insights and Updates from Companies House. If you have a question that isn't answered here please reach out to us at: support@amiqus.co.
FAQs
- Do you need to register with Companies House as an ACSP if your teams register mortgages on behalf of your company clients at Companies House?
- Although there is no requirement for ACSP individuals to be verified, will they need to be verified once those filing on behalf of the company are mandated to be verified?
- Do we need to verify the identity of all members of our LLP before we can file? And also, if we are submitting a confirmation statement on behalf of a client, does every director and PSC of that body need to be verified before we can submit?
- If I am verifying an identity for a person who is not a British citizen, are there additional requirements to verify that person's identity?
- If a client provides us with their Companies House personal code having already been verified by another ACSP, how can we be assured that the other firm has followed the correct process?
- Who completes the sanction checks?
- We have a solicitor's nominee company and our directors have all completed the voluntary ID verification using the OneLogin and received our personal codes. Have we done everything we need to do at this stage until we need to submit our next confirmation statement, at which point we would submit our codes to Companies House?
- My understanding is that we can begin client checks before registering as an ACSP, is that correct?
- Companies House states we must keep records for seven years. Is this an ECCTA or AML requirement? Is this in conflict with the 5-year AML record-keeping requirements?
- If I am a solicitor and verify ID for an individual as an ACSP, am I required to inform Companies House of the ID Verification so that they in turn generate a personal code for the individual to complete registration?
- Would Companies House block or flag it if an email address has already been used for a personal code?
- What is the correct process for notifying Companies House of a client’s change of name? Is this managed via the ACSP portal, and does such a change trigger a requirement to re-do the identity verification process, or is the original verification still considered valid, provided the change is properly recorded?
- In a scenario where a PSC has engaged with two separate ACSP-registered firms and has undergone identity verification with both, and each firm has confirmed to Companies House that verification has been completed, how is this handled? Similarly, if the individual has already verified directly with Companies House but failed to provide their personal code to the ACSP, and then subsequently undergoes verification again through the ACSP, will the individual still receive only one unique Companies House personal code? In other words, is the Companies House system able to recognise the individual and prevent the issue of multiple codes for the same person?
- In what circumstances can a driving licence be accepted as a primary photo ID? The process appears to place emphasis on cryptographic features - does this requirement apply only to passports with biometric chips, or are UK driver's licenses included?
- What advice can you give for clients that do not have passports or driving licences?
- We appreciate that the MLR 2017 requirements differ from those of Companies House. However, if we already verify photo ID and proof of address for AML purposes, would this be sufficient to satisfy Companies House requirements? Or must we repeat the process using NFC-enabled checks purely to meet Companies House obligations?
- If I verify an ID face‑to‑face, do I still need to run cryptographic checks?
- Is there a requirement to upload the ID certificate to Companies House, or is it simply a matter of confirming that the verification has been completed? If confirmation alone is required, what specific information must be provided so that we can request it from clients in advance as part of the IDV process?
- Why are People with Significant Control (PSCs) being treated differently to directors?
- How do PSCs who are not directors upload their personal code if it is not at the same time as filing the CS01?
- Do ordinary shareholders below PSC thresholds require verification?
- How can Amiqus help us fulfil the Companies House requirements?
- Would we still need to complete forgery training if we use Amiqus?
- What are the technology requirements for someone completing an NFC check?
Do you need to register with Companies House as an ACSP if your teams register mortgages on behalf of your company clients at Companies House?
Not necessarily. If you are only filing charges, mortgages, or similar documents at Companies House, you don’t need to be an ACSP to carry out those filings. ACSP registration is specifically required where you are verifying the identity of directors, PSCs, or other relevant individuals. If your role does not include identity verification, you can continue without registering as an ACSP.
However when Companies House mandates presenter requirements currently scheduled to commence in Spring/Summer 2026 anyone filing information on behalf of another company will need to be an ACSP at that point.
Although there is no requirement for ACSP individuals to be verified, will they need to be verified once those filing on behalf of the company are mandated to be verified?
Currently, there is no requirement for individuals within an organisation (such as staff members or partners) to have their identity verified. The verification obligations apply to the directors, PSCs, and relevant individuals of the companies being registered. However, the Companies House regime is evolving, so firms should keep an eye on updates in case future rules extend requirements.
Do we need to verify the identity of all members of our LLP before we can file? And also, if we are submitting a confirmation statement on behalf of a client, does every director and PSC of that body need to be verified before we can submit?
Yes. If you're filing on behalf of your own LLP, each member must have their identity verified before filings can be made. Likewise, if you're submitting a confirmation statement for a client, every LLP member, director and PSC of that client company must also be verified in advance. Companies House stipulates that all relevant individuals linked to the filing are verified before the submission is accepted, so building this into your workflow early will help avoid delays.
The exception to this rule is for PSC’s who are not also directors or members. In these circumstances the requirement is for the PSC to provide their personal code within 14 days of the start of the month of their birth date.
If I am verifying an identity for a person who is not a British citizen, are there additional requirements to verify that person's identity?
The Companies house Identity standard is the same regardless of where an individual comes from. You may need to supplement ID documentation with other information in order to get people up to the Companies House standard. This information can be found in Companies House guidance:
- How to meet Companies House identity verification standard
- Tell Companies House you have verified someone's identity
If a client provides us with their Companies House personal code having already been verified by another ACSP, how can we be assured that the other firm has followed the correct process?
If your client provides you with a code from another ACSP, you can use this to provide the registrar with their ID details when completing their Confirmation Statement or Incorporation details.
You cannot worry whether the other ACSP has completed the process correctly, they have to make a statement that they have ID’d their client to the relevant standard. The Registrar will query any suspicious or erroneous ID’s with the relevant ACSP.
Who completes the sanction checks?
AML & Economic Crime related controls (including sanction screening), and ACSP IDV checks are wholly separate processes. Sanctions screening and other such controls should be undertaken separately by your firm in the normal manner
That said, if the client passes your AML-related IDV checks you can then send the ID credentials to the registrar, provided the these checks meet the required IDV standard.
We have a solicitor's nominee company and our directors have all completed the voluntary ID verification using the OneLogin and received our personal codes. Have we done everything we need to do at this stage until we need to submit our next confirmation statement, at which point we would submit our codes to Companies House?
It appears you have done everything necessary at this stage. When the CS01 is due you can provide the registrar with the details and personal codes of all the directors, PSCs etc.
My understanding is that we can begin client checks before registering as an ACSP, is that correct?
You can undertake client checks and ID for clients before registering as an ACSP. However you cannot provide the ID credentials to the registrar and make relevant statements for your clients until you are registered as an ACSP. Also your clients won’t receive a personal code until the ID process is registered with Companies House.
Companies House states we must keep records for seven years. Is this an ECCTA or AML requirement? Is this in conflict with the 5-year AML record-keeping requirements?
The record keeping requirements under the Money Laundering Regulations are separate from the 7 year requirement under ECCTA. The records must be kept from 7 years following the making of the ID statement with the registrar.
If I am a solicitor and verify ID for an individual as an ACSP, am I required to inform Companies House of the ID Verification so that they in turn generate a personal code for the individual to complete registration?
Yes. If you verify an individual as part of your role as an ACSP, you must report that verification to Companies House. Once submitted, Companies House will generate a personal code for the individual, which allows them to complete their registration. Simply carrying out the verification is not enough; it must be notified via your Companies House account for it to be valid.
Would Companies House block or flag it if an email address has already been used for a personal code?
Yes there should only be one ID per individual. If an e-mail address has already been associated with an Id our system will let the individual or ACSP know this is the case.
What is the correct process for notifying Companies House of a client’s change of name? Is this managed via the ACSP portal, and does such a change trigger a requirement to re-do the identity verification process, or is the original verification still considered valid, provided the change is properly recorded?
Once Identity has been completed and an individual has received their personal code. Any changes to that person's name after that point simply needs to be notified via the relevant Companies House change form.
If an ACSP makes a mistake when providing the ID details to the registrar certain information can be rectified.: e.g.
- Name
- Alternative Name
- DoB
- E-mail address
The ACSP can for now simply email the registrar and provide the following details:
- ACSP Name & Number
- Name of ID individual
- E-mail address used on ID
- ACSP acceptance reference
- Incorrect details
- Correct Details
In a scenario where a PSC has engaged with two separate ACSP-registered firms and has undergone identity verification with both, and each firm has confirmed to Companies House that verification has been completed, how is this handled? Similarly, if the individual has already verified directly with Companies House but failed to provide their personal code to the ACSP, and then subsequently undergoes verification again through the ACSP, will the individual still receive only one unique Companies House personal code? In other words, is the Companies House system able to recognise the individual and prevent the issue of multiple codes for the same person?
In these circumstances an individual will end up with two Id’s and personal codes. The registrar will need to cancel one of them as an individual should only have one ID. You can notify the registrar of this and provide the details of both records and indicate which of the duplicates is not required. The registrar will delete the record and provide a notice when it is completed.
In what circumstances can a driving licence be accepted as a primary photo ID? The process appears to place emphasis on cryptographic features - does this requirement apply only to passports with biometric chips, or are UK driver's licenses included?
Wherever possible, you should try to verify the cryptographic features of a passport.
- How to meet Companies House identity verification standard
- Tell Companies House you have verified someone's identity
For option 1, you must use identification document validation technology (IDVT) to validate the cryptographic features of the document. If the document does not have cryptographic features (for example, if it’s a non-chipped document such as a UK driving licence), the technology you use must be able to validate the physical security features to verify the document.
A fallback option to accept a Driving Licence or National Identity Card is only applicable for:
- Persons who do not have a passport.
- Persons with a passport where no NFC chip is present.
- Persons with a passport with an NFC chip, but it is not compatible with Amiqus (see here)
- Clients who do not have a compatible device (see "What are the technology requirements for someone completing an NFC check?")
What advice can you give for clients that do not have passports or driving licences?
If a client doesn’t hold a passport or driving licence, you can still complete verification using the alternative routes permitted by Companies House. Amiqus supports these by allowing candidates to upload other accepted documents (for example, national ID cards, biometric residence permits, or supporting non-photographic documents combined with other evidence). The platform guides you through what’s acceptable, ensuring you can still complete the check without excluding individuals who lack passports or licences.
If I verify an ID face‑to‑face, do I still need to run cryptographic checks?
If you undertake face-to-face checks your team will need to be trained to spot forged documentation. The right technology is required to read cryptographic features - it may be that you wish to supplement your face-to-face checks with a technical solution to ensure the required standards are met.
Is there a requirement to upload the ID certificate to Companies House, or is it simply a matter of confirming that the verification has been completed? If confirmation alone is required, what specific information must be provided so that we can request it from clients in advance as part of the IDV process?
You only need to provide your client data. You will need to store the relevant documentation for 7 years post ID provision to the registrar. The registrar may require you to provide evidence following a complaint or simply through random auditing of ACSP’s.
Why are People with Significant Control (PSCs) being treated differently to directors?
Not all PSC’s are directors or known to companies as some merely become PSCS by ownership of shares and have no dealing with the company. We felt it would have been unfair for companies with remote PSCs to be impacted because they had no control over the PSC completing ID and in effect it would make the whole company non-compliant.
How do PSCs who are not directors upload their personal code if it is not at the same time as filing the CS01?
The ID information is captured on a Form VS01 which for directors comes in alongside the CS01. PSCs can simply complete a VS01 when the ID becomes due.
Do ordinary shareholders below PSC thresholds require verification?
Shareholders do not need to undergo IDV unless they are a PSC by holding 25% or meet the PSC criteria.
How can Amiqus help us fulfil the Companies House requirements?
Amiqus fulfils ACSP identity verification requirements by covering all the core data points: validation of cryptographic documentation features, along with verification of name, date of birth, and at least 12 months’ address history.
For UK clients, Amiqus integrates with TransUnion to verify their address history. For international directors or PSCs, candidates can securely upload supporting address verification or other required documents through the Amiqus platform. Their identity is then validated using biometric checks, facial recognition, and document verification, all within one secure digital workflow. This means you can confidently demonstrate compliance with Companies House standards while reducing admin overhead.
Please note that to send a compliant request will require that you send a Photo ID check with 'Verify a passport by scanning an NFC chip' selected. This feature is not enabled by default so please contact us, using the details at the bottom of the page, to request this be enabled.
You can see more information in our support article: Creating an Authorised Corporate Service Provider (ACSP) compliant request.
Would we still need to complete forgery training if we use Amiqus?
If you are relying solely on Amiqus’ digital verification process, forgery training is not required for your staff, because the technology performs document authenticity checks, including biometric and cryptographic validation (e.g. NFC chip reading on passports).
It is always advised that training in identifying forged/fraudulent documents forms part of their AML controls at a firm.
However, if you plan to also carry out manual identity checks in your firm (in-person document inspections), staff performing those checks must still undertake forgery detection training to meet Companies House standards.
What are the technology requirements for someone completing an NFC check?
The Amiqus app requires iOS 14.0 or later. iOS 14 is officially supported by iPhone 6 and upwards. You must have access to a mobile device that supports NFC, such as an Apple iPhone 7 or newer or a supported Android device.
An auto-fallback route is built in to our ACSP templates and is available for those without a device that can complete an NFC check. If you would like these templates uploaded in to your account please contact us.
To contact us, please use the support widget on the bottom left of the page or email support@amiqus.co.