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Companies House ACSP Identity Verification Service Engagement Letter Template
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Companies House ACSP- Identity Verification Service
This schedule should be read in conjunction with the engagement letter and our standard terms and conditions.
Introduction
You have engaged us to assist in the identity verification process, ensuring compliance with UK regulations and statutory requirements.
Our role includes handling all legal and administrative aspects of identity verification, ensuring compliance with the relevant legislative frameworks, and structuring the verification process effectively for Companies House.
We conduct the process of Identity Verification as governed primarily by the following legislation:
- The Economic Crime (Transparency and Enforcement) Act, 2023 (“ECTEA”)
- Registrar (Identity Verification and Authorised Corporate Service Providers) Regulations 2025
We do not hold any responsibility for the approval of the identity verification application. We are not liable for any consequences following the submission of your application. Service charges are non-refundable if the application is rejected.
We will only process the information provided to us for the legal purposes for which it was collected. Pursuant to the Economic Crime (Transparency and Enforcement) Act 2023 (ECTEA), we will retain all information provided for identity verification for a minimum of 7 years from the date of completion of the identity checks. This information cannot be returned or destroyed during this retention period. We will not process the information unless we have obtained your consent, or legislation mandates us to do so.
Your Responsibilities
As the director or PSC of the company, you are responsible to:
- Provide accurate, complete, and up-to-date information required for identity verification.
- Ensure that all identity documents provided for verification are legitimate, clear, and verifiable.
- Respond promptly to any requests from us for additional information or documentation necessary for the verification process.
- Cooperate fully with us during the verification process and assisting in addressing any issues that may arise.
- Review the identity verification application and approving the outcome for submission or further action.
- Ensure that the individuals or entities subject to the verification process are compliant with all applicable anti-money laundering (AML) and counter-terrorism financing (CTF) obligations.
- Settle the fees for the identity verification services prior to the commencement of the verification process.
Our Responsibilities
We will be responsible to:
- Conduct the required identity checks and verification with adherence to the applicable regulations.
- Prepare and submit necessary documentation to the appropriate authorities, if required, after successful verification.
- Maintain accurate records of identity verification data and provide it when requested by you or authorities.
- Notify if any updates, discrepancies, or non-compliance issues arise during or after the identity verification process.
- • Retain and handle all data received in strict confidence and in compliance with applicable data protection laws.
Ad Hoc and Advisory Work
The scope of our services provided to you will be only as set out above, and all other services which we may offer are excluded. If you instruct us to do so, we will provide such other ad hoc and advisory services related to compliance, verification, and corporate administration as may be agreed between us from time to time. These services will be subject to the terms of this engagement letter and our standard terms and conditions of business, unless we decide to issue a separate engagement letter. An additional fee may be charged for these services.
Examples of such work include:
- Advising on identity verification procedures for multiple directors, beneficial owners, or overseas entities;
- Conducting reviews of previously submitted identity verification applications and providing rectification guidance where necessary;
- Assisting with verification where complex ownership structures exist, including trusts or corporate shareholders;
- Supporting clients in preparing documentation or representations in the event of Companies House rejecting an identity verification application;
- Providing advisory support for Anti-Money Laundering (AML) compliance where identity verification overlaps with regulatory obligations;
- Assisting with the verification requirements for newly formed entities or during mergers, acquisitions, or restructurings;
- Preparing supporting documents for high-risk individuals where enhanced due diligence is recommended or required;
- Responding to enquiries from regulatory bodies concerning identity verification records or due diligence checks;
- Advising on the new obligations under the Economic Crime and Corporate Transparency Act 2023 or future updates to Companies House verification requirements;
Where specialist advice is required (e.g., legal interpretation, international KYC compliance), we may need to seek this from, or refer you to, appropriate specialists. We will only do so with your prior consent.
Changes in the Law, in Practice or in Public Policy
We will not accept responsibility if you act on advice given by us on an earlier occasion without first confirming with us that the advice is still valid in the light of any change in the law, practice, public policy or in your circumstances.
We will accept no liability for losses arising from changes in the law (or the interpretation thereof), practice or public policy that are first published after the date on which the advice is given.
Limitation of Liability
Our services as detailed above are subject to the limitations on our liability set out in the engagement letter and in our standard terms and conditions of business. These are important provisions which you should read and consider carefully.
There are no third parties that we have agreed should be entitled to rely on the work done pursuant to this engagement letter.
We will not be liable for any direct or indirect loss or damage arising from:
- Incorrect or insufficient information provided by you.
- The outcome of the identity verification process, including any rejection of applications based on verification results.
- Any changes in legislation or regulatory requirements post-verification that may affect the validity of the verification results.
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Companies House Identity Verification Service Engagement Letter Template
Craft engagement letters tailored to your Identity Verification services as an Authorised Corporate Service Provider. Choose from our ready-made template or sign up to FigsFlow to unlock features that make your life easier.
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- Pre-drafted clauses covering ECTEA 2023 and Registrar Regulations 2025
- Easily customisable for different client profiles and verification scopes
- Clearly defined roles, data retention policies, and limitations of liability
- Quick and efficient format designed for legal accuracy and client clarity
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Frequently Asked Questions
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Explore our FAQs to learn how FigsFlow simplifies your workflows and boosts efficiency.
Is this engagement letter template compliant with the Economic Crime (Transparency and Enforcement) Act 2023?
Yes. The template is specifically designed to meet the requirements under ECTEA 2023 and the Registrar (Identity Verification and ACSP) Regulations 2025.
Can I customise this engagement letter for different types of clients or services?
Absolutely. The template is structured to be flexible and can be adapted to suit different business types, ownership structures and verification scenarios.
What happens if my client’s application is rejected?
The template includes clauses clarifying that the service provider is not liable for application outcomes and that fees are non-refundable, in line with expectations up front.
Does FigsFlow store client identity information?
No. FigsFlow provides the infrastructure for engagement letter creation and management but does not store or process client identity verification data.