These days we are drowning in acronyms – and sometimes they can cause confusion!
So I thought it would be useful for me to spell out the significance of TCSP and ACSP and the difference between them.
TCSP
A TCSP is a Trust or Company Service Provider. The term is defined in Regulation 12(2) of the Money Laundering Regulations 2017.
A TCSP is “a firm or sole practitioner who by way of business provides any of the following services to other persons, when that firm or practitioner is providing such services:
- forming a firm;
- acting, or arranging for another person to act as a director or secretary of a company; as a partner of a partnership; or in a similar capacity in relation to other legal persons;
- providing a registered office, business address, correspondence or administrative address or other related services for a company, partnership or any other legal person or legal arrangement;
- acting, or arranging for another person to act, as a trustee of an express trust or similar legal arrangement; or a nominee shareholder for a person other than a company whose securities are listed on a regulated market”.
If a firm or sole practitioner is acting as a TCSP then they need to comply with the requirements of MLR 2017 including ensuring that their AML compliance is supervised (usually by HMRC or one of the professional bodies) and that their supervisor is aware that they are acting as a TCSP (especially where their TCSP activity is additional to other regulated work such as providing accountancy or tax services).
So TCSP is an acronym that relates to compliance with the Money Laundering Regulations 2017.
ACSP
An ACSP is an Authorised Corporate Service Provider. ACSPs are referred to in the Companies Act 2006 (as amended by the Economic Crime and Transparency Act 2023) and the authorisation is by the Registrar of Companies at Companies House.
An ACSP, and only an ACSP, will (when the legislation comes fully into effect) be permitted to file documents (such as annual accounts and confirmation statements) at Companies House on behalf of their clients and may be in a position to satisfy Companies House that the directors and PSCs of companies have been sufficiently identified.
The legislation is being brought into effect in stages in 2025 and 2026.
From 25 February 2025 Companies House will begin accepting applications from firms (such as accountants, tax advisers, bookkeepers and solicitors) to become an ACSP. There will be a one-off authorisation fee of £55 per firm.
From 25 March 2025 it will be possible for individuals (such as company directors and PSCs) to voluntarily have their identity verified to the satisfaction of Companies House.
Later in 2025 Companies House will begin to require company directors and PSCs to have their identity verified to the satisfaction of Companies House. This will be a mandatory part of the process of forming a new company or filing a confirmation statement for an existing company. The directors and PSCs will be able to deal directly with Companies House to verify their identity; or verify their identity with an ACSP and have the ACSP deal with Companies House on their behalf.
From a date (to be announced) in 2026 only ACSPs will be permitted to file documents at Companies House on behalf of their clients or other third parties. This means that, for example, a document to record the appointment of a new director to a company must be filed either by the company to which the director is being appointed or by an ACSP.
In order to file any documents at Companies House for their clients accountants, tax advisers and bookkeepers will be required to have registered to be an ACSP.
So ACSP is an acronym that relates to dealing with Companies House.
I hope that clears up any confusion between TCSP and ACSP.
If you are concerned that your firm’s AML compliance is inadequate, out of date, 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.