It has been indicated that the next changes affecting LLPs (and companies) will start to take effect from “spring” 2025.
Identity Verification
From 25 March 2025, Companies House should be in a position to allow LLP members, company directors and persons with significant control (PSCs) to voluntarily verify their identity.
Identity verification is expected to closely resemble the process with which many are familiar with for anti-money laundering purposes, including providing proof of ID (such as a passport) and proof of address (such as a recent utility bill).
This voluntary process will be replaced by compulsory identity verification as part of the LLP or company formation process and on the appointment of new LLP members or directors – envisaged to be in autumn 2025.
Autumn 2025 will also be the start of the 1 year transition period for existing LLP members and company directors to verify their identities. This will be incorporated into the process of filing annual confirmation statements for LLPs and companies.
This process is expected result in all individuals on the Companies House register having verified their identity by the end of 2026. It is understood that this will impact more than 7 million existing LLP members, directors and PSCs.
Verification of ID – what should firms do?
For professional services firms, this new requirement is likely to be an administrative headache, rather than problematic. Firms should start to plan early for how they will address this exercise. The date for submitting the annual confirmation statement is not necessarily aligned with the LLP or company’s year-end date, and for some firms this might be as early as October or November 2025 (depending also on what Companies Houses mean by ‘autumn’).
Once detailed information about how to verify ID is available, which should be as the voluntary process is rolled-out from March, firms can plan how they will comply.
This might include a centralised effort to gather and submit documentation from partners, perhaps linked to the annual tax return discussion meetings that many firms arrange for their partners in winter/January (for those firms for which it is not too late).
International firms are likely to want to have systems to support non-UK based LLP members. It seems probable that the Companies House system will involve an element of automation and therefore non-standard documentation, such as non UK passports or proof in other languages, might not be accepted as readily as their UK equivalents.
Firms will also need to remember that the 2026 new partner appointments, often taking effect from 1 April or 1 May, will require the verification of those individuals’ ID in order to register the new partners at Companies House.
Authorised Corporate Services Providers (ACSPs)
Eventually, only ACSPs will be permitted to form new companies and LLPs, or file documents on their behalf, because they need to be permitted to verify the ID of the new entity’s members/directors. This means that businesses which wish to assist clients with incorporating new LLPs or companies, such as law and accountancy firms, will need to be ACSPs to offer that service to clients.
Companies House expects to launch this process from spring 2025 (as at early March 2025, this was still not live). By spring 2026, only firms which are ACSPs will be permitted to file documents on behalf of LLPs or companies, including to incorporate entities.
A director or LLP member will need to register their firm as an ACSP. That person can add users to the firm’s account.
One key function for ACSPs will be to verify the ID of people wishing to incorporate new entities.
The ongoing requirements for ACSPs include the following:
- ACSPs must be always be registered with an AML supervisory body (for law firms, the SRA).
- Changes to the ACSP’s information must be notified to Companies House within 14 days.
- If requested by Companies House, an ACSP must provide information about:
- its filings with Companies House
- identity checks it has undertaken to verify someone’s identity for Companies House
- compliance with their legal responsibilities
- Each ACSP must keep records of any identity checks for 7 years, if they have verified someone’s identity for Companies House.
Firms will need to update their systems and processes to ensure compliance, including risk registers. They will want to ensure teams are adequately trained so that the individual’s ID is verified to a sufficient standard.
There will also need to be safeguards to ensure that information provided to the firm for verification purposes is consistent with the information gathered for the firm’s own AML checks. Firms may also need to revisit their information retention policies to ensure that information will be retained for the required 7 years. Firms will also need to consider these responsibilities and information on key events, such as mergers.
The ACSP’s officers e.g. LLP members or company directors, are all responsible for ensuring compliance with the legal requirements, and face fines or criminal prosecution for failures.
Firms should begin considering now whether or not they want or need to be ACSPs.
Firms which do not wish to become ACSPs, or are not eligible because they are not subject to AML supervision, will need to find alternative was to meet client needs in relation to Companies House filings. For example, the firm may establish a relationship with a corporate services provider. Issues such as client confidentiality and data protection, liability for risk and costs will need to be addressed, and terms of business with clients updated accordingly.
Limited partnerships
Companies House reports that it will require limited partnerships to submit more information by the end of 2026.
Accounts reforms
Timelines have not yet been provided for the following reforms:
- all companies/LLPs to file profit and loss accounts
- no option for small and micro companies/LLPs to file abridged accounts
- software-only filing for all accounts
- limit the number of times that a company/LLP can shorten its accounting reference period
