ACSP Enforcement: Why UK Accountants Must Act Now
ACSP enforcement actions signal decisive regulatory shift for UK accountants
- HMRC and Companies House have issued 77 enforcement actions against non-compliant filing agents.
- Spring 2026 deadline makes ACSP registration mandatory for all professional company filings.
- Modest ACSP registration to date despite over 5.4 million UK companies requiring filing services.
In an unprecedented move, HMRC and Companies House have exercised new enforcement powers against filing agents, issuing 50 suspensions and 27 cease orders to accountants, solicitors, and formation agents. These actions represent a significant departure from the traditionally measured approach of UK regulatory authorities.
The scale of enforcement is especially notable when viewed against the current registration landscape. As of December 2025, Companies House has received over 10,000 registrations seeking ACSP though only 884 agents have opted to appear on the public register of Authorised Corporate Service Providers (ACSPs), while the UK companies register contains over 5.4 million incorporated entities.¹ ² Although Companies House estimates that up to 50,000 businesses may apply for ACSP status within the first year of the scheme,³ the current uptake remains modest. Compounding this, the Institute of Chartered Accountants in England and Wales (ICAEW) reports that a significant proportion of early ACSP applications were rejected due to data mismatches between firms and AML supervisory bodies, highlighting the operational challenges many practitioners face.⁴ This disparity underscores the urgency for accountants to act now, as enforcement is already underway and the regulatory gap remains substantial.
Jump to ↓
Understanding ACSP requirements
Identity verification: the critical compliance component
Why immediate registration matters
The broader regulatory context
Practical steps for compliance
Navigating complexity with confidence
Stay ahead of UK regulatory changes
Understanding ACSP requirements
The ACSP regime affects any professional likely to file documents at Companies House, with particular implications for accountants. Registration requires UK-based operations and supervision by an anti-money laundering compliance body such as ACCA, ICAEW, or HMRC.
The registration process involves a one-off fee and online application through the Companies House portal. However, early adopters report implementation challenges while Companies House rejected a significant number of early ACSP applications due to data mismatches, making immediate action advisable rather than waiting until the Spring 2026 mandatory deadline.
Identity verification: the critical compliance component
The regime introduces strict identity verification standards that fundamentally change filing procedures. For accountants seeking to authorise a Director or Person of Significant Control, ACSP registration has already become mandatory. From Spring 2026, ACSP status will be required for any professional filing on behalf of clients.
This represents a material operational change. Practitioners must now verify client identities according to prescribed standards before submitting filings—a requirement that demands process reviews and potential technology investment.
Why immediate registration matters
The enforcement actions demonstrate regulatory commitment to the ACSP framework. Authorities are not operating a grace period or soft-launch approach. Instead, they are actively monitoring compliance and exercising enforcement powers against non-compliant agents.
With only three months until wider mandatory requirements take effect, practitioners face several practical considerations:
- Registration systems are experiencing teething problems typical of new government services
- Identity verification processes require time to establish and embed
- Client communication about new procedures takes planning
- Staff training on verification standards cannot be rushed
Delaying registration until Spring 2026 creates unnecessary operational risk. Early registration allows time to resolve technical issues, refine verification procedures, and ensure seamless client service continuity.
The broader regulatory context
The ACSP regime reflects wider government priorities around economic crime prevention and corporate transparency. The Economic Crime and Corporate Transparency Act 2023 introduced these measures as part of comprehensive reforms to UK company law.
For tax and accounting professionals, this represents another layer of regulatory responsibility. However, it also presents an opportunity to demonstrate professional standards and differentiate compliant practices in an increasingly regulated market.
Practical steps for compliance
Accountants should take immediate action across several areas:
Registration: Complete ACSP registration through the Companies House portal at https://find-and-update.company-information.service.gov.uk/register-as-companies-house-authorised-agent
Process review: Evaluate current filing procedures against new identity verification standards outlined at https://www.gov.uk/guidance/tell-companies-house-you-have-verified-someones-identity
Technology assessment: Consider whether current practice management systems support ACSP verification requirements and Companies House integration
Client communication: Develop clear messaging explaining new verification requirements and potential timing implications for filings
Staff training: Ensure all team members understand ACSP obligations and verification procedures
Navigating complexity with confidence
The enforcement actions signal a regulatory environment where compliance is non-negotiable. For UK tax and accounting professionals, ACSP registration is no longer a future consideration, it is an immediate operational imperative.
Practitioners who act now position themselves ahead of the Spring 2026 deadline, allowing time to refine processes and maintain uninterrupted client service. Those who delay risk enforcement action and potential service disruption at a critical time.
The message from HMRC and Companies House is unambiguous: the ACSP regime is operational, enforcement is active, and compliance expectations are being rigorously applied.
Stay ahead of UK regulatory changes
Thomson Reuters provides integrated solutions for UK tax and accounting professionals navigating regulatory complexity. Discover how Thomson Reuters supports ACSP compliance and streamlines your regulatory obligations: Digita AML: AI-powered anti-money laundering for accountants
To find out more about how the Digita Professional Suite could help you optimise your operations, contact us.
 |