Accountancy firms that act as Authorised Corporate Service Providers (ACSPs) have an important role in helping Companies House maintain accurate and reliable information about company directors and other individuals.

As part of this role, an ACSP must carry out identity verification checks to the standard specified by Companies House. The requirement applies whether the verification is carried out remotely or face to face.

Firms may carry out the checks themselves or use a commercial identity verification provider. However, using an external provider does not transfer responsibility to the provider. The ACSP remains responsible for ensuring that the required checks have been completed and that the information supplied by the individual is reliable.

Failure to meet the required standard could result in Companies House suspending or preventing the business from acting as an authorised agent.

Establishing the individual's identity

The verification process starts by obtaining key information from the individual. This should include:

• their full name, including any previous names
• date of birth
• residential address
• address history covering the previous 12 months
• email address.

The firm should ensure that the information obtained is sufficiently detailed to enable the subsequent identity checks to be completed effectively.

Acceptable evidence of identity

The next stage is obtaining appropriate documentary evidence. There are two routes available, depending on how the documents are verified.

Where identification document validation technology (IDVT) is used, the technology must validate the relevant security features of the document, including cryptographic and physical security features (such as holographs) where applicable.

The individual can provide one acceptable photographic identity document, such as a biometric or machine-readable passport, an eligible photocard driving licence, an EU biometric identity card, certain UK immigration documents or an eVisa.

There are specific rules concerning documents that have expired. Firms should therefore check the Companies House requirements applicable to the particular document rather than automatically rejecting every expired document.

Where documents are checked by a person, a different evidential requirement applies. The individual generally needs to provide either:

• two photographic identity documents from the specified list such as passport, ID card with biometric information, UK biometric residence permit – read the full list – or
• one photographic identity document together with one document providing additional evidence, such as a birth certificate, bank statement, mortgage statement, council tax statement or utility bill – read the full list.

Where the individual lives outside the UK, at least one of the documents must be government-issued.

Firms should also be aware that cancelled or replaced documents cannot be accepted simply because they appear otherwise valid. The document requirements should be checked carefully before completing the verification.

Checking that documents are genuine

Obtaining an identity document is not sufficient. The firm must also take reasonable steps to establish that the document itself is genuine. View the guidance on examining identity documents.

Where a member of staff examines documents, they should be appropriately trained to identify fraudulent or altered documents. Companies House cannot recommend any specific training providers but they must follow the Home Office best practice guide.

The document should be examined for signs of:

• alteration or tampering
• damage affecting personal information
• inconsistencies in the information provided
• other characteristics that may indicate that it is not genuine.

Where there are concerns, the firm should consider contacting the issuing authority or another authoritative source to confirm the validity of the document. For documents issued outside the UK, the relevant embassy may also be contacted where appropriate.

Establishing that the identity belongs to the individual

The firm must go beyond checking whether the documents appear genuine. It must establish that the identity represented by those documents belongs to the individual being verified.

The name and date of birth provided should correspond with the identity documents.

Where a photograph is available, the firm should compare it with the individual. For remote verification, the firm's process should enable the person's face to be clearly seen so that an appropriate comparison can be made.

Additional checks may be appropriate where there is an increased risk that the identity could be fabricated or misused. For example, firms may wish to obtain further evidence where the documentation does not adequately establish the individual's 12-month address history or where the individual has recently changed their name.

The firm should also consider whether there is evidence that the individual is a genuine, active person. Depending on the circumstances, this could include evidence such as recent bank or credit card activity, utility or council tax bills, insurance documentation or evidence showing that a passport has been used over time.

These additional checks should be applied proportionately and according to the firm's assessment of the circumstances and risk.

Using commercial identity verification services

An ACSP may use a commercial identity verification provider or platform. This can make the process more efficient.

However, the use of technology does not remove the ACSP's responsibility. Before relying on a provider, the firm should satisfy itself that the provider's process covers all the checks required by Companies House. If the provider only completes some of the required checks, the firm must undertake the remaining checks itself.

The firm should also retain evidence of its assessment of the provider and be able to explain why it considers the verification process appropriate.

In other words, outsourcing the mechanics of verification does not mean outsourcing accountability.

Record keeping is an essential part of the process

ACSPs must retain records of the identity verification process for seven years from the date the checks are completed.

The records should include the evidence and information relied upon, including copies of identity documents and evidence of the checks undertaken.

Records should also be retained where an identity verification attempt is unsuccessful. This is important because the firm needs to be able to demonstrate to Companies House what checks were undertaken and why it reached its conclusion.

Firms should therefore ensure that their record-keeping systems are capable of producing a clear audit trail for each verification.

Reporting a successful verification

Once the ACSP is satisfied that the individual's identity has been verified to the required standard, it must notify Companies House through the relevant online service.

The ACSP will need to provide information about the individual and the documents used, including relevant document details such as the reference number, expiry date and country of issue where applicable.

The ACSP does not submit copies of the identity documents to Companies House as part of the notification. However, those documents and the firm's verification records must be retained for seven years.

Practical considerations for accountancy firms

For accountancy firms acting as ACSPs, identity verification should be treated as a formal compliance process rather than simply an administrative exercise.

Firms should consider:

• documenting their identity verification procedures clearly
• ensuring staff understand the required checks and how to identify potentially fraudulent documents
• assessing any commercial identity verification provider before relying on its services
• retaining sufficient evidence to demonstrate how each verification decision was reached
• ensuring unsuccessful verification attempts are also recorded
• maintaining records for the required seven-year period
• periodically reviewing procedures against the latest Companies House requirements.

The use of technology can make identity verification quicker and more efficient, but it does not replace professional judgement. The ACSP must remain satisfied that the individual is who they claim to be and that every required element of the Companies House verification standard has been completed.

The key principle for ACSPs is therefore simple: using an external provider or technology may assist with the process, but responsibility for meeting the Companies House identity verification standard remains with the authorised agent.