Reliance on Companies House verification for AML Customer Due Diligence

Accountants are familiar with the AML Regulations and the need to carry out CDD on all clients, which includes verifying identities. Since 18 November 2025 and being introduced on a rolling 12-month basis, all company directors, Persons with Significant Control (PSCs) and members of Limited Liability Partnerships (LLPs) have been legally required to verify their identity with Companies House. 

This has led to some accountants asking if they can rely on the Companies House identity verification (IDV) as a form of meeting their own CDD identity verification requirements for clients. 

While the two processes both involve the identification of an individual’s identity, you cannot rely on the Companies House verification for your own client verification obligations as they are not interchangeable requirements. Each is a distinct legal requirement under separate legislation.   

The Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (the AML Regulations) state that a relevant person must identify and verify their customers. The AML Regulations also permit a relevant person to rely on CDD done by another relevant person, but a contractual arrangement must be entered into between the two AML relevant persons.  Companies House is not a relevant person for the purposes of the AML Regulations and as a result the provision set out in the AML Regulations cannot be used for these purposes. 

The AML Regulations also say that relevant persons do not satisfy the requirements to verify and identify a beneficial owner of the customer by relying solely on information delivered to the registrar of companies under any enactment that requires information to be delivered to then about registrable persons, registrable relevant legal entities or registrable beneficial owners. 

While the AML Regulations deals specifically with beneficial owners (BOs), it is our view as an AML supervisor, that the same level of risk applies to all those which CDD covers as it does to BOs, and as a result the same level of prohibition set out in legislation for BOs can, and should, be applied against all CDD identity verification checks. 

As a reminder of your responsibilities under the AML regulations, your firm is required to carry out CDD on all clients you work with and retain evidence that this has been done. The purpose of CDD is to know and understand your client’s identity and any business activities they are involved in, so that any money laundering, terrorist and proliferation financing risks can be understood and managed. As part of CDD, firms are required to identify their clients. That is, they must understand who they are and then verify this by obtaining documents or other information from independent and reliable sources. This may be done within your firm, you may be using AML software for part of the CDD obligations, or you may be using an electronic identity service provider to carry out the verification process.  

Whilst it’s important to know that you cannot rely on the IDV at Companies House for client identification purposes, if a client has been unwilling or unable to do this at Companies House then this should be considered as part of the risk profile of the client and they will be unable to file any statutory filings online with Companies House.

Visit the ICAS AML hub  for more resources on the requirements and how you can ensure compliance with them.