Learn the difference between ACSP and TCSP status, why both matter for nominee director services, and the due diligence checks overseas founders should make before appointing a UK nominee director provider.

ACSP vs TCSP: What to Check Before Choosing a UK Nominee Director Provider

Nominees / nominee director

If you are choosing a UK nominee director provider, two compliance labels matter far more than they once did: ACSP and TCSP. They are not the same thing, and a provider that cannot explain the difference may not be the right fit for an overseas founder or corporate group. In 2026, good due diligence is no longer just about price and speed. It is about checking whether the provider sits inside the right UK compliance framework for identity verification, anti-money-laundering supervision and lawful corporate-service delivery.

Compliance concept image showing UK nominee director due diligence, ACSP registration and TCSP supervision checks

Why this distinction matters now

An Authorised Corporate Service Provider is a Companies House authorised agent. A Trust or Company Service Provider is a business category supervised under the UK money laundering regulations where certain corporate services are provided by way of business. A nominee director provider may need one, the other, or both depending on what it is doing. In practice, overseas clients should understand both.

Before appointing a provider, check whether it can clearly explain:

  • its anti-money-laundering supervisory body
  • whether it is registered as an ACSP for Companies House identity-verification work
  • how it handles identity verification and Companies House personal codes
  • how it approaches nominee director appointments, governance and record keeping
  • how it deals with PSC disclosure and transparency requirements
  • whether its service is described as compliance support rather than secrecy or concealment

This matters because nominee-director work sits close to both company law and anti-money-laundering controls. A provider may be offering a genuine, well-governed corporate service, or it may be using vague language around privacy and “local presence” without the right compliance infrastructure behind it.

For international founders considering a UK nominee director service, the best starting point is to check the provider’s regulatory footing before discussing the appointment terms. That is especially important where the provider also offers non-resident company formation or a registered office address service.

It is also worth keeping one point clear from the outset: UK companies do not generally need a UK-resident director, although many overseas owners still choose a nominee arrangement for local presence, continuity or administration. That commercial choice does not reduce the legal importance of the appointment itself.

What ACSP status means in practice

An ACSP is a Companies House authorised agent. To register, the business must be supervised by a UK anti-money-laundering supervisory body. For now, agents that plan to verify identities for Companies House need ACSP registration. From no earlier than November 2026, filing on behalf of clients as an authorised agent is also due to require ACSP registration.

In practical terms, ACSP status matters when a provider is involved in the identity-verification process for directors or PSCs. It is also relevant where the provider expects to interact directly with Companies House systems as an authorised agent. Companies House requires ACSPs to keep identity-check records for 7 years and to notify changes to their details within 14 days.

That means ACSP status is not just a badge. It is a compliance role with ongoing obligations. A provider that markets itself as handling Companies House identity verification should be able to explain exactly how it satisfies those obligations and who inside the business is responsible for them.

What TCSP supervision covers

HMRC guidance says a trust or company service provider includes a business that forms companies, provides registered offices or correspondence addresses, or acts or arranges for another person to act as a director or secretary. HMRC also lists businesses providing nominee director, nominee company secretary and nominee shareholder services among the types of business that should register for supervision where relevant.

That is why TCSP supervision is highly relevant to nominee-director services. It shows that the provider is operating inside the anti-money-laundering supervision framework for the kind of service it is selling. It should also mean the provider is carrying out risk assessment, customer due diligence, record keeping and related controls in a structured way.

For overseas company owners, this distinction is useful because it helps separate a serious regulated provider from a website that only looks professional. TCSP supervision is one of the clearest questions to ask before relying on any provider to introduce or supply a nominee director.

Nominee directors, transparency and legal duties

A nominee director is still a director. Companies House guidance says directors are legally responsible for running the company and making sure information is sent to Companies House on time. Separate Companies House guidance also explains that the seven statutory duties under the Companies Act 2006 still apply even if the director is not active, someone else tells them what to do, or they have not been formally appointed in the usual way.

That point matters because some marketing language around nominee arrangements can suggest the role is purely symbolic. It is safer and more accurate to say that nominee arrangements must still be documented, governed and operated in a way that respects company law, transparency rules and the director’s continuing legal obligations.

It is equally important to avoid any suggestion that a nominee director removes beneficial-ownership disclosure. It does not. Where the PSC regime applies, the company must still identify and report people with significant control. In limited protection cases, a PSC may apply to have information protected from public view where there is a serious risk of violence or intimidation, but that is a separate statutory process and not a substitute for reporting.

ACSP vs TCSP: side-by-side comparison

The table below highlights the practical difference between these two compliance concepts when you are choosing a nominee director provider.

Status What it means for a nominee director provider
ACSP Companies House authorised-agent status. Relevant where the provider verifies identities for Companies House and, from no earlier than November 2026, where it files on behalf of clients as an authorised agent.
TCSP AML-supervised corporate-services activity under the money laundering regulations. Relevant where the provider forms companies, supplies registered office or correspondence addresses, or acts or arranges for others to act as directors, secretaries or similar officers.
Both Often the strongest practical position for a regulated nominee-director provider that also supports Companies House identity-verification workflows and broader corporate-service delivery.

In many cases, the safest commercial choice is a provider that can evidence both the anti-money-laundering supervision expected for corporate services and the Companies House authorisation needed for identity-verification work.

A practical due-diligence checklist

Before appointing a provider, ask direct questions and look for direct answers. Good providers should not be evasive about their status, process or limits.

Question to ask Why it matters
Which AML supervisory body supervises you? This helps confirm whether the provider is supervised for the kind of regulated corporate services it offers.
Are you registered as an ACSP? This is essential if the provider says it can verify identities for Companies House or handle those workflows as an authorised agent.
How do you handle personal codes and identity-verification statements? A provider should understand the current Companies House process for directors and PSCs.
How do you document the nominee appointment and authority boundaries? A well-run service should be supported by clear contractual and governance documents rather than informal arrangements.
How do you explain PSC disclosure to clients? A compliant provider should not imply that nominee services remove PSC obligations or public-register rules.
Do you work with overseas founders as part of a broader company setup? This helps you assess whether the provider can lawfully and coherently support the full structure, not just the appointment itself.

If you want to compare regulated options, CG Incorporations’ about us page and contact page provide a clear starting point for overseas founders who need nominee-director and UK corporate-services support.

FAQs

No. An ACSP is a Companies House authorised agent. A TCSP is a business category supervised under the money laundering regulations for certain corporate services. A provider can be one, the other, or both.

Not in every scenario today. At present, agents that plan to verify identities for Companies House need ACSP registration, and filing on behalf of clients as an authorised agent is due to become mandatory from no earlier than November 2026.

Where the business is carrying on trust or company service provider activity by way of business, it should be supervised under the money laundering regulations unless it is already supervised by another recognised supervisory body.

No, not in the ordinary course. Using a nominee director does not remove the company's obligation to identify and report PSCs where the PSC regime applies.

Yes. A nominee director is still a director. Directors remain legally responsible for company filings and owe statutory duties under the Companies Act 2006, including acting in the company's best interests and exercising independent judgement.

Red flags include unclear AML supervision, no clear ACSP process for identity verification, marketing that implies a nominee can be used to conceal beneficial ownership, and weak documentation around governance, authority and record keeping.

Published: 3/27/2026 11:00:47 AM. Disclaimer: This article is for informational purposes only and does not constitute legal or financial advice.
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ACSP vs TCSP: What to Check Before Choosing a UK Nominee Director Provider

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