Authorised Corporate Services Provider

In our latest thought leadership, Simon Drewett, Managing Director at Altum, explains the benefits of partnering with a premier Authorised Corporate Services Provider (ACSP).

Escalating economic crime: A UK perspective
The scale of economic crime in the UK has grown significantly in recent times, to the point it now runs to tens or even hundreds of billions of pounds each year. Historically Companies House has not sought to verify the accuracy of information filed on its register making it relatively easy for those conducting nefarious activities to register fake companies, officers and people with significant control.

Interim measures and legislative evolution
Short term measures were introduced in the Economic Crime (Transparency and Enforcement) Act 2022 to prevent sanctioned bodies from shielding UK property in ‘overseas entities’, however, following the passing of the Economic Crime and Corporate Transparency Act 2023 (ECCTA), Companies House is now on a path of transformation from passive recipient of company information to pro-active gatekeeper. Its objective is to improve data transparency and accuracy in order to support confidence in business decisions and also facilitate prosecutions against those perpetrating corporate economic crime.

The first set of ECCTA reforms were introduced on 4th March 2024 and gave Companies House important new tools to improve the integrity of the corporate information it holds, including:

• Enhanced powers to interrogate, reject and correct information submitted to it,
• A new requirement for companies to provide an email correspondence address and a tightening of the rules relating to registered office addresses, and
• A requirement for companies to make an annual lawful purpose statement.

An additional, more radical reform set to take effect in the near future (after secondary legislation has been passed) introduces an identity verification requirement for:

• All new and existing company directors,
• People with Significant Control (PSC), and
• Those delivering documents to Companies House.

Introducing the Authorised Corporate Services Provider
To streamline verification, the ECCTA introduces the concept of the ACSP, a regulated  intermediary registered with a regulatory body for anti-money laundering purposes. Upon activation of the relevant  provisions, only ACSPs will be able to deliver documents to Companies House and complete the mandatory new identity (re)verification requirements by issuing corresponding ‘verification statements’ for their clients.

In due course, most submissions to Companies House in relation to limited partnerships and limited liability partnerships will necessitate an ACSP’s involvement. These submissions include:

• Applications for registration,
• Changes of registered office/email address,
• Changes to officers of GPs,
• Alterations relating to partners and  changes in partnership structures,
• Annual confirmation statements.

What are the consequences of not complying?
Failure to verify the identity of a director will be classed an offence, although importantly the validity of the actions taken by that director will not be affected. It will also be an offence for any person, without reasonable excuse, to deliver a document to Companies House that is “misleading, false or deceptive in a material particular”.

Anticipated penalties for non-compliance
While the full extent of penalties set out in the regulations is yet to be defined, the consequences of non-compliance are expected to include:

• Criminal proceedings,
• Civil penalties issued by the Registrar,
• Incorporations being rejected,
• Inability to file statutory filings,
• An individual’s status being noted as ‘unverified’ on the public register, and/or
• Prevention from acting as a director.

Understandably those with less experience in carrying out AML checks or who are responsible for numerous UK corporate entities may want the help of an expert ACSP.

How can Altum Group help you?
At Altum we consider the identity verification process a positive change, and one which is long overdue. Whilst the new process necessitates an additional step in dealing with Companies House, we believe it will breed confidence that information held by Companies House in relation to UK companies is legitimate and that an individual’s information cannot be altered by fraudsters. Domestic and overseas investors carrying out due diligence on potential investment opportunities will be assured that they are dealing with genuine registered individuals and business entities.

We use industry leading technology to efficiently onboard complex fund structures and are also able to provide all necessary incorporation, domiciliation, directorship and company secretarial services relevant to UK companies. Once established our team of experienced asset class specialists is perfectly placed to perform all of the UK entity’s ongoing governance, administration, accounting and reporting functions.