ECCTA identity verification: what accountants must do now

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) introduced the most significant reforms to Companies House in decades. For accountants, the most immediate obligations are around director and PSC identity verification.

What ECCTA requires

ECCTA introduced mandatory identity verification for all directors, PSCs (Persons with Significant Control), and those who file on behalf of companies. Verification must take place:

• For new appointments: before or at the point of appointment filing
• For existing directors and PSCs: by a transitional deadline set by Companies House

Agents who file on behalf of clients must also verify their own identity through the Companies House authorised agent route.

How verification works

Identity verification is done through one of two routes:

• Direct verification — individuals verify themselves directly with Companies House using an approved digital identity service
• ACSP route — an Authorised Corporate Service Provider (ACSP) — typically an accountant or agent — verifies identity on the client's behalf

To act as an ACSP, firms must register with Companies House and meet anti-money laundering compliance requirements.

Impact on confirmation statements

From the implementation date, confirmation statements include a new lawful purpose statement — directors must confirm the company's intended future activities are lawful. This cannot be omitted from the filing.

Additionally, confirmation statements now capture more granular share capital data, including share class details and share rights.

What this means for your practice

• Register as an ACSP if you file on behalf of clients
• Identify all existing directors and PSCs who require verification
• Build ID verification into your new client onboarding process
• Update engagement letters to reflect the new obligations
• Brief clients: failure to verify could prevent them from making any future Companies House filings