Companies House Reform: Updated Compliance Timelines and IDV Requirements
As we progress through 2026, several key components of the Economic Crime and Corporate Transparency Act (ECCTA) have been subject to revised timelines.
For ICB members, these updates provide clarity on when specific filing and verification obligations will become mandatory.
1. Accounts Filing Reforms: Formal Delay
The proposed requirement for small and micro-entity companies to file a Profit and Loss account and a Balance Sheet has been formally paused.
Under the original ECCTA roadmap, micro-entities were set to lose their exemption from filing a P&L, and small companies were to be mandated to file a P&L, a Balance Sheet, and their audit reports (where applicable). However, Companies House has confirmed that these reforms are currently under review.
* 21-Month Notice: The government has committed to providing a minimum of 21 months’ notice before any such changes to accounts filing are implemented.
* Current Status: Small and micro-entities should continue to follow existing filing regulations for the time being.
2. Authorised Corporate Service Providers (ACSP) and Filing
There has been an update regarding the requirement for agents to register as an Authorised Corporate Service Provider (ACSP).
* Filing on Behalf of Others: Currently, you may continue to file via Companies House on behalf of clients provided you maintain active AML supervision and provide your ICB Licence Number where required.
* Delayed Mandatory Registration: The requirement for all third-party agents to be registered as an ACSP to submit filings was originally slated for Spring 2026. This has now been delayed until at least November 2026.
* IDV Responsibility: Registration as an ACSP is only strictly necessary if a practice wishes to verify the identities of its clients' officers directly. If a practice performs this service, they will be recorded by Companies House as the ACSP who conducted the verification.
Note on Liability: Many practitioners are choosing not to register as an ACSP for IDV purposes. By directing clients to use the GOV.UK One Login service or the Post Office for verification, the administrative responsibility and the liability for the identity check remain with the individual and the government service. Members should be aware that Companies House IDV requirements are distinct from standard AML-related CDD checks.
3. Mandatory Identity Verification (IDV) for Directors and PSCs
While filing reforms have been delayed, the transition period for Identity Verification is firmly underway. This requirement applies to all Directors and Persons with Significant Control (PSCs).
* The Transition Period: Having commenced on 18 November 2025, the 12-month window to verify existing officers is active.
* Deadlines for Existing Officers: All existing directors and PSCs must have completed their IDV by 17 November 2026.
* Directors: Must typically verify by the time the company files its first Confirmation Statement after 18 November 2025.
* PSCs: If a PSC is not also a director, their verification deadline is often linked to their month of birth.
* New Appointments: Any individual appointed as a director or notified as a PSC after November 2025 must complete verification as part of the appointment process.
Next Steps for ICB Members
Members are advised to notify their clients of the impending November 2026 deadline for Director and PSC identity verification. Directing clients to the GOV.UK One Login service now will ensure they are compliant well in advance of the deadline without requiring the practice to take on additional regulatory responsibilities as an ACSP.
