Now that the new identity verification rules are in force, Authorised Corporate Service Provider (ACSP)s are operating under a much tighter Companies House regime. New filings can no longer proceed unless people with significant control (PSCs) have been properly verified, and the expectations around evidence and accountability have increased.
This shift is much more than a procedural update. It is also important to be clear that Companies House (CH) identity verification is a separate statutory obligation, distinct from your duties under the Money Laundering Regulations (MLRs). CH rules set out specific, prescriptive identity-checking steps for all relevant company officers and PSCs. AML obligations, by contrast, are risk-based and focus on preventing money laundering, terrorist financing and proliferation financing.
Meeting CH verification requirements does not, on its own, mean you have met your wider AML responsibilities.
Companies House now expects verification to be carried out to a standard that mirrors the principles in the MLRs, especially around evidence and audit trails. For many firms this brings clarity. For others it exposes gaps that were previously hidden by inconsistent filing practices or incomplete beneficial ownership checks.
If your AML framework is already solid, the change should feel manageable. And AMLCC users are already in a strong position, as the platform’s identity checks and audit trails meet the expectations underpinning the new rules. But you’ll also need to make sure you use the platform’s record-keeping functions to align with the more prescriptive CH standard while still applying a risk-based approach for AML.
Below is a practical AML-focused checklist that sits alongside Companies House guidance, to help every firm (AMLCC user or not) stay compliant and maintain smooth filing workflows – and to highlight where CH and AML obligations overlap and where they remain separate.
1. Treat Companies House verification as part of your AML – but not a replacement for it
The new identity verification requirements work hand in hand with AML duties, but they do not replace them. CH verification is required by company law and must be completed in a prescribed way for all relevant directors and PSCs. AML requirements under the MLRs are separate and are based on the level of risk in the client or transaction.
Firms often complete a risk assessment for a client but rely on incomplete or unverified PSC information when filing corporate updates. That gap will no longer be tolerated.
You’ll need to ensure that:
- Verification of directors and PSCs feeds directly into your client risk assessment
- PSC discrepancies are treated as AML red flags rather than Companies House admin issues
- Overseas PSCs, high-risk jurisdictions and non-face-to-face onboarding trigger enhanced due diligence
- Verification evidence aligns with how you evidence CDD under the MLRs
CH verification can also play a clear role within your CDD framework. When onboarding a corporate client, it provides an independent and authoritative source for confirming the identities of directors and PSCs, strengthening the “identify and verify” stage of CDD. CH checks also support ongoing CDD for existing clients by helping you track changes in ownership and control over time.
Treating CH verification as an extension of CDD creates consistency across your AML and corporate filing work and provides a stronger foundation in the event of a supervisory review – but remember that AML still requires you to go further where the risk is higher.
If a client has completed the CH verification process directly, then you cannot rely on that process for your AML and you will need to complete the verification process for your firm. Companies House own verification does not include a proof of address check and you must have seen the verification checks carried out and hold a copy on your files.
2. Your ID verification must meet both prescriptive CH rules and risk-based AML standards
Companies House has set minimum verification standards that are prescriptive. They spell out how verification must be carried out for all relevant PSCs and directors, regardless of the level of risk.
At the same time, ACSPs must meet AML standards. When an inspector looks at your AML, they will expect any verification you have completed for both Companies House and your AML obligations to be robust. That means:
- Using tools capable of robust ID, biometric and fraud-risk checks
- Maintaining clear, retrievable evidence of each verification (AMLCC already handles this)
- Applying higher scrutiny where sector guidance expects it
- Ensuring verification can be repeated during ongoing monitoring
- Including a proof of address check to prove an individual has the right to the identity they are claiming.
3. Your confirmation to Companies House now carries AML weight – but is a separate legal step
Submitting a confirmation that identity verification is complete is no longer a neutral filing step. It is a statutory CH requirement in its own right and a compliance action that may be examined later by Companies House. Your internal processes should:
- Prevent anyone from filing before AML and Companies House checks are complete
- Create a clear audit trail for both AML and corporate filings
- Flag situations where verification cannot be completed safely.
Consider introducing a dual sign-off process: one for AML completion and one for Companies House submission. This adds protection and avoids accidental or unauthorised filings.
4. Companies House record-keeping obligations align with AML audit expectations
Many firms underestimate the level of detail Companies House may request. Its new powers include the ability to require ACSPs to show exactly how a verification was conducted. The standard is very close to the expectations set out in Regulation 40 of the MLRs.
As an ACSP, you must be able to produce:
- Evidence of how each person was identified and verified
- Records of PSC mapping, ownership chains and control
- Notes on enquiries made around complex structures or overseas links
- A timestamped history of activity and decisions.
This level of documentation often makes the difference between a smooth AML review and a finding of non-compliance. It also helps you show that you have met both CH and AML record-keeping duties, even though they arise from different legal frameworks.
5. Complex ownership structures need to be treated as AML red flags
The new regime shines a light on corporate chains, nominee arrangements and opaque company structures, which are all common AML risks. Firms sometimes accept PSC information at face value because Companies House filings used to be permissive and lightly checked. That is no longer the case.
You’ll need to ensure:
- PSC identification follows the MLRs and Companies House rules
- Explanations for complex structures are tested and not taken at face value
- Overseas entities, politically exposed persons (PEPs) and layered structures trigger enhanced due diligence
- “Verification incomplete” is treated as a risk decision, not an admin delay
This aligns naturally with the AML risk-based approach. If beneficial ownership cannot be verified confidently, under your AML and now your Companies House obligations, there is an increased risk and you need a written process to deal with the situation.
6. Build Companies House verification into AML onboarding and ongoing monitoring
The new verification rules should sit alongside your AML workflow. This avoids inconsistencies where AML files show one story and Companies House filings show another.
If you think it will help your staff, write this process into your AML policies, controls and procedures (PCPs) so that:
- PSC information feeds into your AML risk assessment automatically
- High-risk triggers escalate to your MLRO before any filing
- Staff understand that AML and ACSP duties overlap but are not the same and must each be satisfied.
From a CDD perspective, CH verification should be treated as an additional trusted source for confirming the identities of directors and PSCs at onboarding and a useful tool for ongoing CDD, helping you track changes in ownership and control over time.
This is especially important for smaller firms where the same person handles AML and corporate work.
Final thoughts
Identity verification, PSC analysis and beneficial ownership mapping are already core AML expectations. The new Companies House rules formalise the link between corporate transparency and AML compliance and introduce a more prescriptive framework for verifying company officers.
However, CH verification is its own statutory requirement and does not, on its own, meet your wider AML obligations. AML remains risk-based and focused on preventing money launderiny, terrorist financing and proliferation financing, with duties around risk assessment, ongoing monitoring and enhanced due diligence.
Firms using AMLCC to its full potential are already meeting the verification standard Companies House requires, with the added benefit of a full AML audit trail behind every check.
The priority now is alignment and clarity: ensuring your AML processes, filing workflows and ACSP duties all operate as one system – while staying clear that CH rules and AML obligations are related but separate, and both must be met in full.
About Richard Simms
Richard Simms, Managing Director of AMLCC, is a leading authority on anti-money laundering compliance, risk management and education who has worked as a hands-on regulated professional himself. Since the 2007 introduction of AML regulation for UK accountants, Richard has seen first-hand the challenges of implementing effective AML processes.
Working with regulatory supervisors, Richard used his professional insights to create AMLCC (Anti-Money Laundering Compliance Company Limited) in 2008 to make AML easier for regulated businesses worldwide.
