There is so much going on in the world of AML for accountants, bookkeepers, tax advisers, auditors and TCSPs at the moment that I thought this month I needed to provide an update on several areas. So here we go!
Companies House ID verifications
We are now just over half-way through the 12 months ID verification period which commenced on 18 November 2025. So how are the figures looking?
The latest statistics I have are as at 15 May 2026. On that date there were 9,396,427 directorships on the record at Companies House. Of these 3,901,969 had verified IDs, which is 41.5%. But of course 100% of directors appointed on or after 18 November 2025 will have a verified ID, and that is at least 760,000 directorships. When we take that into account it appears that no more than 36.4% of directorships in existence on 17 November 2025 have so far been verified.
There were on 15 May 2026 1,341,084 directorships without a verified ID for which the due date for verification had already passed. We can infer that there are a lot of companies who have overdue Confirmation Statements.
The figures for PSCs are worse. On 15 May 2026 there were 6,679,038 PSCs entered on PSC Registers at Companies House. Of these PSCships 2,022,021 had verified IDs, which is 30.3%. Again 100% of new PSC registrations on or after 18 November 2025 will have a verified ID, and that is at least 550,000 PSCships. When we take that into account it appears that no more than 24.0% of PSCships on the register on 17 November 2025 have so far been verified.
There were on 15 May 2026 1,233,702 PSCships without a verified ID for which the due date for verification had already passed.
In a nutshell, Companies House are a long way short of 50% verification at the half-way stage.
Amendment to MLR 2017
The government is in the process of amending MLR 2017 (again). The amending Statutory Instrument has been published in draft. It is expected that it will be formally ‘made’ on 9 June, which means that most of the amendments will come into effect on 30 June 2026 (21 days after the SI is ‘made’).
The most significant change for accountants is that amounts currently expressed in Euros will be redefined in Sterling, for example 10,000 euros will become £10,000. Most figures will be translated one-for-one, but there are some variations.
Also the expression “complex or unusually large” will be replaced by “unusually complex or unusually large in each case given the nature of the transaction”. This makes clear that ‘large’ or ‘complex’ needs to be viewed in context.
There are also new provisions relating to cryptocurrency businesses, but these will not come into force until 2027.
New CCAB AML Guidance for the Accountancy Sector
We are expecting a revised edition of the CCAB AML Guidance for the Accountancy Sector (AMLGAS). The current edition was published in June 2023. I understand an updated version is in draft and will be published in the next few months, once the draft has been approved by HM Treasury.
Transfer of AML Supervision to the FCA
As you will know, the government has decided that the Financial Conduct Authority (FCA) should become the AML supervisory body for accountants, bookkeepers, tax advisers, auditors and TCSPs (Trust or Company Service Providers). The supervisory role for these businesses will be removed from the professional bodies and HMRC and transferred to the FCA.
This will not happen any time soon – the transfer is at least two years away. In the meantime it will be ‘business as usual’ for the existing supervisors.
The transfer process will involve the passage of an Act of Parliament, then the making of subordinate legislation by Statutory Instruments. There will also be a need for the FCA to promulgate new AML guidance and to develop its own teams of supervisors. So it is expected that there will be no changes on the ground until at least late 2028.
If you are concerned that your firm’s AML compliance is inadequate, or even non-existent, get in touch now using the link below and we can work together to fix this. The hardest part is getting started.
