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Aipedia: Company formation and secretarial agents
Companies House has published no AI guidance for authorised corporate service providers (ACSPs), so its general ACSP standard governs every AI-assisted check. An ACSP whose identity checks fall short can be suspended or ceased, which would remove a core service for a formation agent.
Part of: AI in Company formation and secretarial agents
In short
Authorised corporate service providers (ACSPs) are AML-supervised firms and sole traders that Companies House authorises to carry out identity verification and other work for clients. Their identity checks must give the same level of assurance as verifying directly with Companies House. Companies House carries out random checks on ACSP data and may suspend or cease a provider that does not meet the standard. No AI-specific guidance exists from Companies House, HMRC or the professional bodies for this work, so AI tools are judged by the same standard as any other method.
An authorised corporate service provider, also called an authorised agent, is a firm or sole trader that Companies House has authorised to act for clients, including verifying their identity. ACSPs carry out AML-supervised activity, such as company formation, legal, accountancy or chartered secretarial work, and Companies House requires every ACSP to be AML-supervised.
Formation agents are trust or company service providers (TCSPs) under the Money Laundering Regulations 2017. Their AML supervisor is HMRC where no professional body supervises them, or otherwise their professional body, such as ICAEW, ACCA or the Law Society/SRA. There is no statutory regulator specific to formation agents, so the ACSP regime is the closest thing to sector-specific oversight.
The wider picture of AI use, risk and insurance across the sector is in AI in company formations: rules, risks and PI.
The table summarises the position as at October 2026.
| Body | What it has published | Status | AI-specific? |
|---|---|---|---|
| Companies House | Identity verification requirements under the Economic Crime and Corporate Transparency Act 2023 regime, from 18 November 2025 | Legal requirement | No |
| Companies House blog, 11 December 2025 | ACSP checks must match the assurance of GOV.UK One Login; random checks; suspension or cessation | Statement of how Companies House supervises ACSPs | No |
| HMRC as AML supervisor | Supervision of TCSPs under the Money Laundering Regulations 2017 | Regulations are binding | No AI guidance found |
| ICAEW and ACCA | Code of ethics technology provisions and PCRT AI guidance | Code applies to members; PCRT is guidance | General AI provisions, not specific to secretarial work |
| SRA | Rules for solicitors and law firms | Binding on regulated firms | See the solicitors pages |
| Chartered Governance Institute UK & Ireland | Professional body for company secretaries | Membership standards | No company secretarial AI guidance found |
For the accountancy provisions, see ICAEW, ACCA and CCAB AI guidance explained. For agents working within law firms, see AI in law firms.
The timetable below sets out what applies now and what is still to come:
A verified person receives an 11-character personal code to give Companies House for each role. Failure to verify is an offence and can lead to a financial penalty and blocked filings. The detail is on the Companies House identity verification pages. Once the filer stage applies, the people at an agent who submit filings will also be within the regime, which is a further reason to keep clear records of who filed what.
The central rule for ACSPs is that their identity checks must give the same level of assurance as verification directly with Companies House through GOV.UK One Login. In a blog post on 11 December 2025, Companies House explained that it does the following:
As at October 2026 there was no published AI-related suspension, court decision, Companies House sanction or AML enforcement action involving a formation agent's use of AI.
Neither Companies House nor HMRC has published AI-specific guidance for ACSPs or TCSPs. That does not leave AI unregulated. It means AI tools are judged by outcomes: does the check meet the Companies House standard, does the AML process meet the Money Laundering Regulations, and is the work done with reasonable care and skill under section 13 of the Supply of Goods and Services Act 1982?
Data protection is where specific rules do bite. Face matching uses biometric data, which is special category data when used to identify someone, so a DPIA is needed. An automated verification refusal may be a solely automated significant decision under UK GDPR Articles 22A to 22D, in force from 5 February 2026. In practice, an ACSP using AI should be able to explain how its tool reaches the required assurance, show human oversight of borderline cases and produce records on a random check. The detail is in AI identity checks for Companies House and deepfake IDs and forged documents.
Points to watch include any Companies House guidance on AI-generated or manipulated documents submitted by presenters, and how HMRC approaches AI-assisted customer due diligence in its TCSP supervision.
There is no statutory PI requirement for formation agents or ACSPs, and Companies House does not set one for ACSPs. Agents within ICAEW, ACCA or SRA-regulated firms are subject to those bodies' PI rules. For other agents, PI is a commercial decision, although clients, banks and business partners commonly expect it.
The ACSP regime changes the risk in two ways. A suspension or cessation would disrupt the agent's business, and its own lost income is usually not a PI matter. Separately, clients whose filings stall because of a failed or false verification may claim their losses, which PI commonly covers subject to the wording. Fines and AML penalties are commonly excluded or uninsurable; see are fines and penalties covered by PI? and does formation agents' PI cover AI errors?.
Apex arranges PI for ACSPs and other corporate service providers. A broker checks that your policy reflects identity verification work and explains how it would respond if a Companies House review led to client claims.
As at October 2026, Companies House had published no AI guidance for presenters or ACSPs. ACSPs are judged by the general standard: identity checks must give the same assurance as verification directly with Companies House through GOV.UK One Login.
Yes. Companies House says it carries out random checks on ACSP data, investigates potential issues and may suspend or cease an ACSP that does not meet the standard. Suspended and ceased ACSPs are listed on GOV.UK.
No earlier than November 2027, with at least six months' notice, according to Companies House. Directors, PSCs and LLP members have been required to verify since 18 November 2025, with a 12-month transition for existing people.
Formation agents are trust or company service providers under the Money Laundering Regulations 2017. HMRC supervises them where no professional body does; otherwise their professional body, such as ICAEW, ACCA or the Law Society/SRA, is the supervisor.
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