An accountancy firm becomes a trust or company service provider (TCSP) under regulation 12(2) of the Money Laundering Regulations 2017 if, by way of business, it forms companies, sells off the shelf companies, provides a registered office or business address, acts or arranges for someone to act as a director, secretary or partner, or acts as a trustee or nominee shareholder. Regulation 56 then forbids it from acting as a TCSP unless it is on HMRC’s TCSP register. For a firm supervised by ICAEW or another professional body, that body passes its details to HMRC, but the firm must declare the work accurately.

Which services make a firm a TCSP?

Regulation 12(2) defines a trust or company service provider as a firm or sole practitioner who by way of business provides any of these services to other persons:

  • forming a firm (any entity other than an individual, including companies, partnerships and LLPs);
  • selling an off the shelf firm, added from 30 June 2026;
  • acting, or arranging for another person to act, as a director or secretary of a company, a partner of a partnership, or in a similar capacity for other legal persons;
  • providing a registered office, business address, correspondence or administrative address or other related services for a company, partnership or other legal person or arrangement;
  • acting, or arranging for another person to act, as a trustee of an express trust or as a nominee shareholder (other than for a company listed on a regulated market).

The work does not need to be a separate business line. ICAEW’s TCSP helpsheet says it notifies HMRC of every supervised firm doing TCSP work, including firms where that work is incidental to accountancy services. The National Risk Assessment, as summarised by ICAEW, continues to rate TCSP services as high risk for money laundering, with the risk greatest where formation is combined with other accountancy services to create complex structures.

Does providing a registered office address count?

Yes. It is the most common way an ordinary practice becomes a TCSP without noticing. HMRC’s guidance confirms that mailbox services for a company, partnership or similar legal person are TCSP services, including providing a registered office address that meets Part 6 of the Companies Act 2006, a correspondence address where the client is not physically present, and virtual office services. The same services provided only to sole traders or private individuals are not TCSP work.

One technical point: regulation 4(2) treats formation, off the shelf sales, officer services and trustee or nominee services as a business relationship whether or not the work is expected to last, but registered office services are not on that list. In practice a registered office arrangement nearly always has an element of duration, so customer due diligence and ongoing monitoring apply anyway. The company law side of the address is covered in registered office address rules.

What changed for company formation and off the shelf companies?

The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 inserted regulation 12(2)(ab) from 30 June 2026. Regulation 12(3) defines an off the shelf firm as one that either does not carry on business, or carries on business that is not the main activity of the TCSP. HMRC’s guidance adds that an off the shelf sale includes selling a pre existing firm you bought to hold dormant, and distinguishes it from formation because the firm was not formed on a specific customer’s instruction.

Regulation 4(2) was amended at the same time, so a single sale of a shelf company is now treated as a business relationship. ICAEW’s summary of the 2026 CCAB guidance says TCSPs selling off the shelf companies must now comply with all MLR obligations, including CDD and ongoing monitoring. A practice that keeps a few dormant companies ready for clients who want to start trading quickly should treat each sale as a new client engagement with full customer due diligence.

When does acting as a director, secretary or trustee count?

HMRC’s guidance gives a narrower picture than the regulation alone suggests:

  • Arranging has a narrow meaning, such as providing a client with a director selected without further reference to the client and completing the appointment formalities. Ordinary recruitment does not count.
  • Officers. An individual acting as director, secretary or partner on a limited basis does not need to register, unless the business is high risk or in a high risk jurisdiction. Nor does someone acting for the company that employs them, or a company acting for another member of its group.
  • Trustees. Acting, or arranging for someone to act, as a professional trustee of an express trust is TCSP work, except for certain low risk trusts such as straightforward will trusts creating life interests for spouses or for beneficiaries under 25.
  • Nominee shareholders are always within scope unless acting for a listed company.

A partner who acts as company secretary for a client company as part of the firm’s paid service may bring the firm within scope, and the firm should check whether any exclusion genuinely applies before deciding otherwise. The duties of the role are described in the company secretary role.

What does “by way of business” mean?

HMRC lists four questions: does the firm carry out one or more TCSP activities; does it advertise or publicise the activity or receive referrals; does it aim to make a profit from it; and does it carry it out with reasonable or recognisable continuity. If all four apply, the firm is acting by way of business. A practice that offers its address to company clients for a fee, and mentions the service on its website, will meet this test easily.

Who registers, and with whom?

Regulation 54(2) requires HMRC to keep a register of TCSPs not on the FCA register, and regulation 56(1) prohibits anyone from acting as a TCSP unless included in it. The route depends on supervision:

Firm’s position What happens
Supervised for AML by a professional body such as ICAEW, ACCA or AAT The body continues to supervise and passes the firm’s details to HMRC for the register. ICAEW does this where a firm answers yes to its annual return questions AML07a to AML07e.
Not supervised by a professional body or the FCA The firm applies to HMRC for supervision and registration and must not act until HMRC confirms success. A fit and proper test is part of the application.

HMRC’s supervision handbook says most UK TCSPs are accounting and legal professionals supervised by professional bodies, with HMRC supervising around 6%. Regulation 58 requires the registering authority to refuse registration if the applicant, an officer, manager or beneficial owner is not fit and proper, and regulation 58(6) lets HMRC rely on a professional body supervisor’s opinion. More on supervision generally is in AML supervision for accountants.

What if a firm provides TCSP services without being registered?

Regulation 56(1) is a “relevant requirement” listed in Schedule 6, so contravening it is a criminal offence under regulation 86, punishable on indictment by up to two years’ imprisonment, a fine or both. It is a defence to show the person took all reasonable steps and exercised all due diligence. ICAEW also warns that performing TCSP work while not on the register may lead to disciplinary action. For a professional body supervised firm, the practical safeguard is answering the TCSP questions on its annual return correctly.

How does TCSP status relate to Companies House authorised agents?

They are separate. An Authorised Corporate Service Provider (ACSP) is an agent registered with Companies House, for now needed to verify identities for Companies House. Companies House guidance says an ACSP must always be registered with at least one AML supervisory body, must report changes within 14 days, and must keep records of identity checks for seven years. Being an ACSP does not make a firm a TCSP, and TCSP registration does not make it an ACSP. See Companies House identity verification.

Where do practices go wrong?

Illustration only. A two partner practice lets 40 company clients use its office as their registered office for £50 a year each, forms about ten companies a year, and one partner is a paid company secretary for three clients. It told its supervisor it does no TCSP work. All three activities are TCSP services. The firm should correct its annual return so it appears on HMRC’s register, add TCSP risks to its firm wide risk assessment, and check that each registered office client has current CDD and beneficial ownership information, including the register checks described in reporting PSC discrepancies.

Other common mistakes:

  • forwarding post for dormant or former clients without any current CDD;
  • selling shelf companies after 30 June 2026 without treating each sale as a new relationship;
  • overlooking partners acting as trustees of client trusts.

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Reviewed by Christine Anderson, Broker, Solar Protect. Last reviewed 8 October 2026. Part of Accountapedia, the Solar Protect guide to UK tax and accounting. This page is general information, not personalised advice.