Published: 8 November 2024 6:19 am Author: Oliver Stanley
Latest IDV & ECCTA implementation update from Companies House (and Kudocs)
Key Takeaways
- Spring/ Summer 2025:
- Companies House hopes to start allowing third parties (i.e. professional advisers) to apply to become an ACSP – so that they can complete IDV for their clients and clients’ stakeholders.
- Individuals will be able to apply directly to Companies House (via OneLogin) to verify their identity.
- Autumn/ Winter 2025:
- All existing directors will have 12 months to verify their identity at Companies House (using their personal code). This will be when filing the next confirmation statement that falls due in this 12 month period.
- All relevant stakeholders will need to include their personal code in new incorporations.
- All relevant stakeholders will need to include their personal code when being appointed as a new director or PSC.
- PSC IDV can be provided separately to incorporation, confirmation statement or when being notified via a new interface to be developed by Companies House (with which Kudocs will integrate).
- During 2026:
- Anyone filing information through to Companies House (ie as a presenter) will need to verify their identity.
- Any third party agents filing on behalf of companies will need to be registered as an ACSP.
- Companies House be able to reject documents delivered by disqualified directors.
- Companies House will require all limited partnerships to submit more information, providing greater transparency for users of the register.
- Companies House will be implementing new address standards.
Disclaimer: this post is based on recent informal discussions with Companies House, who was happy for us to share the details of our conversation. All of the information is indicative only at this stage as Companies House is still clarifying the details of how and when implementation will take place. For more specific information, please contact Kudocs directly (we will share anything we can) or seek professional advice.
Companies House implementation timelines
Companies House continues to make progress towards implementation of the IDV requirements under ECCTA. While no substantial change to working processes will be required until approx the middle of 2025, there are various preparatory steps that are due to come into effect around Spring 2025. These include the ability for professional advisors to start registering as ACSPs and for individuals to start completing their own IDV via OneLogin. The requirement to complete IDV is due to only become mandatory after Summer 2025.
What will be the verification standard for IDV by ACSPs?
Draft Registrar’s Rules have been published alongside the draft Regulations. The Rules set out the various standards for ID verification. From our review of this, the standards are likely to be similar to current ID verification requirements imposed by existing AML obligations (e.g. from the SRA, ACCA, ICAEW, etc). Therefore, at this stage, we hope that if you are complying with existing AML requirements under your existing regulatory obligations, there will be no extra IDV requirements imposed by virtue of being an ACSP.
The draft rules state:
Individuals verifying their identity through an Authorised Corporate Service Provider registered with Companies House must use evidence from one of the options lists below:
Option 1 – Only one piece of evidence is required if the individual can provide one of the
following AND the ACSP ca n validate cryptographic features
- Biometric or Machine – Readable Passport or Irish Passport Card
- UK, Channel Islands, Isle of Man and EU photocard driving licence
- EU or EEA identity card , with biometric information
- UK biometric residence permit
- UK biometric residence card
- UK Frontier Worker Permit
Where an individual does not have evidence from Option 1 or the ACSP cannot validate the
cryptographic features:
Option 2 – Two pieces of evidence are required if the individual cannot verify through Option 1 – either two pieces of evidence from Group A, or one from Group A and another from Group B:
| Group A | Group B |
|
|
How will Kudocs support these changes?
It is a bit early to be able to answer this definitively, not least because Companies House has not yet published the changes they will be making to their technical infrastructure. That said, we’d imagine it would be along the lines of requiring our users to enter (i) their ACSP ‘code’ in some part of the system as part of their own account management and (ii) the personal code for any relevant stakeholders as part of their profiles when adding or editing them – it could be another field alongside name, date of birth and address etc.
We are certain of one thing – whatever the changes, we’ll make them as easy and simple for our customers to use and comply with.
Address standards
Another change that Companies House is working on is to bolster the quality of addresses submitted to the Registrar. This is not such an issue when using Kudocs as we have our own minimum requirements (such as Building name/ Address Line 1/ Town/ Postcode), but Companies House will be moving their address standards in line with ours – and BS7666 and the UK Government Open Standard. This means that as a minimum, all addresses will need:
- Building name
- Street name
- Postcode
How this will work with non-UK addresses which may not have all of these parameters, remains to be seen!
As ever, Kudocs will continue to provide updates or answer any questions you may have. For more information about the IDV process, see our earlier blog post here.
Useful Links
Contact Info
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Kudocs Ltd, Floor 3 Marlborough House, Victoria Road South, Chelmsford, Essex, CM1 1LN
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info@kudocs.co.uk
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kudocs.co.uk