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Aipedia: Company formation and secretarial agents

AI in company formations: rules, risks and PI

Company formation and secretarial agents can use AI for drafting, filing and checks, but no UK rule moves responsibility away from the agent. Since identity verification became law on 18 November 2025, errors in AI-assisted checks, filings and documents carry regulatory as well as civil consequences.

In short

No UK regulator has published AI guidance for formation agents or authorised corporate service providers (ACSPs), so existing duties apply in full. Agents are trust or company service providers under the Money Laundering Regulations 2017, ACSPs must verify identity to the same assurance level as Companies House, and services must be performed with reasonable care and skill. AI errors in articles, minutes, PSC entries, filings or identity checks become the client's public record and can lead to claims. PI may respond to civil claims, subject to the wording, but AML and regulatory fines are usually outside cover.

How formation and secretarial agents use AI

Formation agents, company secretarial firms and the accountants and solicitors who offer corporate services handle a high volume of repetitive, rules-driven work. That makes the sector an obvious place for AI, which now appears at most stages of the client journey, typically in these tasks:

Each of these tasks produces something that a client, a bank, an investor or Companies House relies on. When a tool gets it wrong, the error often becomes part of the public register and may surface years later, at a sale, a funding round or a shareholder dispute.

Who regulates formation agents

There is no statutory regulator specific to formation agents. Three layers of oversight apply instead, summarised in the table.

BodyRoleAI guidance
Companies HouseRegisters companies and authorises ACSPs, also called authorised agents, who must be AML-supervisedNone found for presenters or ACSPs
AML supervisor: HMRC, or a professional body such as ICAEW, ACCA or the Law Society/SRASupervises trust or company service providers (TCSPs) under the Money Laundering Regulations 2017None found specific to TCSPs
Professional bodies, including the Chartered Governance Institute UK & IrelandSet conduct standards for company secretaries, accountants and lawyersNone specific to company secretarial work

Agents supervised by an accountancy body are subject to its technology provisions and AI guidance, explained in ICAEW, ACCA and CCAB AI guidance explained. Agents inside law firms fall under the SRA framework covered in AI in law firms.

Identity verification and the ACSP standard

Under the Economic Crime and Corporate Transparency Act 2023 regime, identity verification became a legal requirement on 18 November 2025 for directors, PSCs and LLP members, with a 12-month transition for existing people. 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. Verification will extend to people who file at Companies House no earlier than November 2027, with at least six months' notice.

ACSPs can verify identity for clients, but their checks must give the same level of assurance as verifying directly through GOV.UK One Login. In a blog post of 11 December 2025, Companies House said 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. Any AI document or selfie check an agent relies on has to meet that bar.

The main AI risks for formation agents

Most claim scenarios come back to an unchecked AI output being filed, signed or relied on. The recurring risks are these:

The duty of care does not change because a tool was used. For business clients, section 13 of the Supply of Goods and Services Act 1982 implies a term that the service will be carried out with reasonable care and skill. For consumer clients, many of whom buy formations online, section 49 of the Consumer Rights Act 2015 does the same.

How PI usually responds

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. No regulator or insurer has published a statement on AI and formation agent PI.

In general, a PI policy responds to civil claims arising from the professional services described in the schedule, and many wordings may not distinguish between work done by hand and work done with AI. Cover usually depends on the services being declared accurately, so an agent that has added AI identity verification, automated filing or a chatbot should tell its insurer. AML fines and regulatory penalties are commonly excluded or uninsurable, and data breaches tend to sit with cyber cover. See PI for company secretaries and corporate services and does PI cover AI mistakes?.

Aipedia guides for company formation agents

The guides below cover each area in more depth, from the ACSP rules to specific AI tasks:

How Apex helps

Apex arranges PI for company formation agents, company secretaries and corporate service providers. A broker reviews how your services are described on the schedule, how the policy treats AI-assisted work and where PI stops and cyber or crime cover takes over.

Sources

Frequently asked

Do formation agents need to tell Companies House they use AI?

As at October 2026, Companies House had published no guidance on AI for presenters or ACSPs. What matters is the result: identity checks must give the same assurance as verification with Companies House, and filings must be accurate. Record how AI is used so you can show your checks if asked.

Is PI compulsory for company formation agents?

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 must follow those bodies' PI rules, and many clients and business partners expect cover in any case.

Can an ACSP use an AI tool for identity verification?

Yes, if the checks give the same level of assurance as verifying directly with Companies House through GOV.UK One Login. Companies House carries out random checks and can suspend or cease an ACSP that falls short, so both the tool and the human review around it matter.

Will PI pay an AML fine if an AI risk tool missed something?

Usually not. Regulatory fines and penalties are commonly excluded from PI or uninsurable. Some policies cover defence costs for regulatory investigations, and a separate civil claim from a client may fall within cover, depending on the wording.

Check your PI covers how you use AI

Tell us about your firm and the work you do. A broker will review how your current PI treats AI-assisted work, or arrange new cover. No fee for a quote. Or call 0117 325 0027.

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Apex Insurance Brokers Limited is authorised and regulated by the Financial Conduct Authority. Registered in England and Wales, company number 07014570. This page is general information about how AI is used in the profession and how insurance may respond. It is not legal, regulatory or insurance advice on your circumstances, and it does not guarantee that cover will be available or on what terms.