As approximately half of all company formations and filings are presented by third parties, it is also a requirement that third parties are ID verified before they can file or deliver documents on behalf of other people or companies.

It may be a company secretary or employee of a company making the filing. They will also need to be ID verified.

As many filings are outsourced to third party agents, these bodies will need to confirm they are supervised and registered with Companies House before they will be permitted to form companies or make any filings on behalf of their clients/customers.

From no earlier than November 2027, Companies House is expected to begin to enforce identity verification for all presenters of information, making it a compulsory aspect of filing any document.

Company Secretaries

The inclusion within the identity verification regime of those filing at Companies House on behalf of another entity or individual, will capture most company secretaries. 

Considering this upcoming requirement, it is advisable for a company to authorise the company secretary to file documents on its behalf or to state which documents may be filed on it behalf, for example, the company's accounts. This should be documented in board minutes.

If a company secretary files on behalf of the company's directors and PSCs, it may also be adviable to obtain a letter of authorisation as to this from each individual concerned. 

Neither of these are a legal requirements, but it provides protection for the company secretary should a potential dispute arise in relation to these filings. 

Requirements to act as a Third Party Agent

Third party agents must be registered with a supervisory body for anti-money laundering purposes (and have this confirmed) and are required to conduct Customer Due Diligence checks, under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017. 

Third parties will also be required to submit evidence of the ID verification checks they are responsible for when they interact with Companies House. Registration will also allow third parties to conduct the ID verification checks that will allow directors, partners of LLPs and PSCs etc to open an account with Companies House.

Third party agents are likely to be Authorised Corporate Service Providers (ACSPs) and be bodies such as accountants, lawyers and company formation agents etc.

Registration Process as a Third Party Agent

The director or equivalent of a third party, whose ID has already been verified, will submit the contact details of the third party and information about its supervision to Companies House online. This information will then be cross matched with data that is held by HMRC. If supervision is confirmed, the third party agent will be given credentials which will enable them to make filings or form companies or partnerships with Companies House.

The process aims to be quick and easy.

Third Party filings

When it applies to form a company (or other registrable entity) or to file on a company’s (or other registrable entity’s) behalf, a third party will need to provide evidence of its credentials. The third party will also be required to list the ID verification checks that they have carried out on each prospective director (or equivalent) or details of the director’s (or equivalent’s) account(s) that already exist for those persons. They will also be required to declare that they are satisfied that all relevant ID checks have been carried out.

Companies House will only register entities if they are satisfied that the checks that have been conducted on all directors (or equivalents) are to at least the same standard as those required by Companies House themselves when verifying directors. 

Companies House will inform the supervisory body of third party agents that are registered with it. Information as to anomalous, suspicious, or incorrect filings that a third party makes with Companies House may be shared with that supervisor. Ultimately whilst primary responsibility for action against a rogue third party agent lies with their supervisor, Companies House will have the power to terminate the registration of a third party if the supervisor fails to take appropriate action and the nature of the risk is considered sufficiently serious. Information may also be shared with other appropriate bodies such as law enforcement agencies.

Fit and Proper Purpose Test

In August 2026, Companies House published guidance on the criteria it will consider when deciding whether someone is a "fit and proper" person to carry out the functions of an ACSP. This guidance can be accessed here.

An ACSP must be trustworthy, competent and compliant.

Under section 1098B of the Companies Act 2006, Companies House will not register an applicant as an ACSP if they appear not to be fit and proper. Companies House will also monitor ACSPs and may suspend or terminate their ACSP status if they have reasonable cause to believe they are no longer fit and proper.

The guidance published by Companies House sets out a non-exhaustive list of areas and criteria which Companies House may consider as part of its fit and proper assessment, including:

• eligibility and competence to act as an ACSP, including whether the ACSP (or applicant) has appropriate Anti-Money Laundering (AML) supervision;
• criminal, regulatory and financial history such as bankruptcy or disqualification as a director;
• honesty, integrity and conduct, including in its previous dealings with Companies House; and
• history with Companies House and ACSP activity, such as how the ACSP carries out IDV and its compliance with statutory filing requirements.

Companies House may also look at aggravating factors as part of its assessment, such as repeated patterns of behaviour, as well as mitigating factors such as co-operation with Companies House.

Importantly:

• a past problem will not automatically disqualify the ACSP (Companies House will consider the current status);
• repeated or unresolved problems are much more serious;
• being AML-supervised does not automatically make the ACSP “fit and proper”. Companies House will make its own assessment;
• the test continues after registration. Companies House can suspend or remove an ACSP if concerns arise; and
• an ACSP must provide complete and accurate information and tell Companies House about relevant changes.

An ACSP must be registered with at least one AML supervisory body, but the guidance emphasises that meeting the AML supervision requirement does not automatically mean that the fit and proper test is satisfied. Companies House filings and client verification processes must also be clean, accurate and well documented — and the ACSP is expected to deal promptly with any compliance problems.