December 18, 2025 Companies House Begins Suspending ACSPs & Why Law Firms Are Sitting Out
For some time, we’ve been told Companies House has greater enforcement powers and wouldn’t be afraid to use them. We’ve now seen a demonstration of this when it comes to Authorised Corporate Services Providers (ACSPs), the agents who are currently verifying the identities of thousands of individuals under the Economic Crime and Corporate Transparency Act (2023).
77 ACSPs Ceased or Suspended
Companies House first began publishing information about suspended and ceased ACSPs in October 2025 (9 months after ACSP registration began). The latest figures, as of December 2025, show that 50 ACSPs are currently suspended and 27 have ceased status. Suspended means the ACSP is temporarily barred from acting while issues are investigated or information is requested. Ceased means the ACSP is permanently removed from the register and cannot act as an ACSP. The latest information can be found here.
SRA Firms make up only 3% of ACSPs
The ACSP register is overwhelmingly dominated by Corporate Service Providers and Accountancy firms. This is similar to patterns seen for UK Regulated Agents as part of the Register of Overseas Entities, where 10 of the top 10 providers were TCSPs (Trust and Company Service Provider), with Elemental being the number 1 provider.
To be an ACSP, a provider must be AML regulated by a UK Supervised Body. According to Companies House, there are over 10,000 registered ACSPs. Of these, close to 900 have requested to appear on the public register, which can be found here.
Based on the public register, the vast majority of ACSPs (94.4%) are regulated by HMRC or an accounting or tax body. By contrast, only 3.1% are SRA regulated (3.6% across all UK law bodies). While this analysis is necessarily limited to publicly available data, the disparity is striking. For context, the SRA regulates 8,965 solicitor firms, yet only 27 appear on the public ACSP register.
| Category | Number of ACSPs | % of Total |
|---|---|---|
| Accounting & Tax | 610 | 69.0% |
| HMRC | 226 | 25.6% |
| Law | 32 | 3.6% |
| Other | 16 | 1.8% |
| Total | 884 | 100% |
- Law: SRA, Law Society of Scotland, Bar Standards Board
- Accounting & Tax: AAT, ACCA, ICAEW, CIMA, FCA, IFA, ICB, AIA, IAB, ICAS, ATT, ICAI, CIOT
- Other: Faculty Office of the Archbishop of Canterbury, Insolvency Practitioners Association
Why Aren’t Law Firms Registering as ACSPs?
The low participation rate among law firms reflects regulatory caution, commercial reality, and long-standing risk signals from legal regulators. In July 2022, just before the Register of Overseas Entities was introduced, the Law Society urged members to exercise “extreme caution” before considering verification.
The Solicitors Regulation Authority (SRA) has repeatedly flagged TCSP work as high risk for money laundering and regulatory scrutiny. The number of SRA-regulated lawyers registered as TCSPs fell by around 12% between November 2020 and June 2024, reflecting a steady move away from this area.
Elemental MD Nick Lindsay said: “The discussions I’m having are largely about risk allocation and value. ACSP work brings additional exposure, particularly given the enhanced liability around wrongful filings under the Economic Crime and Corporate Transparency Act. For many firms, this isn’t core legal work, and when they assess it through a client lens, they’re asking whether running this in-house genuinely delivers best value for money. In many cases, they conclude that specialist providers are better placed to do it efficiently and at scale. Law firms have stayed away from identity verification and are now evaluating their position on ACSP filings ahead of spring 2026”
From spring 2026, Companies House filings made on behalf of another party will need to be submitted by a registered ACSP or an identity-verified individual. For law firms that are not ACSPs, this means the ability to file directly for clients will fall away. With only a small percentage of the c. 9,000 solicitor firms known to be registered as an ACSP at present, this raises a broader question about how the remainder of the profession will respond.
To ACSP, or Not?
Law firms are deciding whether to register as ACSPs or rely on specialist providers. In practice, many will adopt a hybrid model, keeping some essential and time-critical filings in-house, such as bank charges, while outsourcing the rest.
But hybrid is not the easy middle ground it appears. It can introduce more complexity, not less: extra processes to map, more training across teams, and additional checks and balances to keep arrangements defensible. That means clear roles, strong quality assurance, and governance that satisfies both regulators and clients. Without this structure, hybrid risks being fragmented and high-risk.
We’re working with firms now to review their approach. If you’d like to explore what this could look like for your firm, get in touch, and we’d be happy to explore options. Elemental is a registered ACSP helping law firms and their clients to meet the Identity Verification requirements. Find out more here.
