January - March 2026 Edition
New Year, New Reforms
As we approach the end of January, I want to take a moment to thank bookkeepers across our membership for the extraordinary work you do at what is, for many, the busiest time of the year. With the tax year end and self-assessment deadlines converging, the pressures on your time and energy are significant. Against this backdrop, you are also navigating an evolving regulatory landscape, with new requirements emerging across AML, Companies House reform and sanctions.
Your professionalism and resilience in balancing these demands do not go unnoticed, and I am grateful for the vital role you play in upholding trust and integrity across the profession.
Sarah Palmer, IAB CEO
Changes to the UK Sanctions List – From 28 January 2026
From 28 January 2026, the UK will move to a single consolidated sanctions list for all UK designations. This replaces the previous two-list approach and reflects the Government’s increasing use of sanctions as a foreign policy and enforcement tool. The sanctions regime is dynamic, with updates made frequently.
Practices must ensure they do not breach – or facilitate the breach of – financial sanctions through their work with clients. Doing so is a criminal offence.
Sanctions checks should be:
- Proportionate
- Risk-based
- Applied at appropriate points in your client lifecycle
This change does not introduce a new obligation, but it reinforces the need for practices to remain alert and ensure that sanctions screening forms part of an effective AML framework.
HMT Annual AML Supervision Report
HM Treasury published its latest annual report on AML supervision in December: Anti-money laundering and countering the financing of terrorism: Supervision Report 2024–25
The report covers supervisory activity across all sectors subject to the Money Laundering Regulations, including performance within the accountancy sector and the supervisory activity of the IAB.
The data draws on the same statistical information presented in our Regulation 46A report, published last quarter, where we provide deeper commentary on IAB-specific supervisory outcomes.
Companies House Reform – What’s Coming Next
Companies House continues to roll out its reform programme, with further changes due over the next quarter. These reforms form part of the wider transformation programme we have signposted in previous editions of Edit. A full roadmap of change is available on the Companies House website, setting out what is coming and when.
As you’ll be aware, the Economic crime and corporate transparency (ECCT) Act introduced new requirements for identity verification and from 18 November 2025, identity verification has become a legal requirement. Anyone setting up, running, owning or controlling a company in the UK must verify their identity to prove they are who they claim to be.
In the future, those submitting information to Companies House (‘presenters’) will also be required to be identity verified or registered as an Authorised Corporate Services Provider (ACSP). This relates to the filing of any statutory document.
Companies House has confirmed the Spring 2026 due date for presenter measures has been postponed until no earlier than November 2026. That means that by no earlier than November 2026 Companies House should be able to:
- make identity verification of the presenters a compulsory part of filing any document
- require third party agents filing on behalf of companies to be registered as an ACSP
This is to prioritise the completion of the identity verification transition period for directors and PSCs, and to give us more time to address stakeholder feedback. They have updated the Economic Crime and Corporate Transparency Act outline transition plan on GOV.UK and our Changes to UK company law website to reflect this.
From 1 February 2026, some Companies House fees will change.
These reforms are not isolated changes – they represent a fundamental shift in how the UK company register operates, with a stronger focus on transparency, identity assurance and data integrity.
Companies House Reform – Changes at a Glance
https://changestoukcompanylaw.campaign.gov.uk/changes-at-a-glance/
What do you need to do?
- Keep sight of the wider reform programme
- Build future Companies House changes into your compliance planning
- Ensure staff understand the direction of travel
Charity Sector Risk Assessment
Many IAB-supervised practices act for clients in the charity sector. The Government has published its latest Charity Sector Risk Assessment 2025.
While not exclusively AML-focused, the report provides valuable insight into the risks present within the sector. Many of the issues identified:
- Indicate potential abuse or misuse
- Highlight vulnerabilities that could lead to predicate offences
- Point to circumstances where proceeds of crime could arise
These underlying risks are directly relevant to AML and CTF obligations. They can help practices better understand where criminal exploitation may occur and where enhanced scepticism is required.
What do you need to do?
- Consider whether you act for charities or related entities
- Use the report to inform your client and sector risk assessments
- Reflect relevant risks in your AML framework
IAB Supervisory Themes and Findings
Policy & Procedure – Still a Key Weakness
Across recent supervisory activity, Policies and Procedures continue to be an area of weakness. Many practices have strong operational processes in place, but these are not being reflected in their formal documentation, as required by the Regulations.
A common issue is over-reliance on generic templates, with little tailoring to reflect how the practice actually operates. This creates a gap between “what you do” and “what your documents say you do” – and it is this gap that is often identified during supervisory reviews.
Your Policies and Procedures must be:
- Practice-specific
- Kept under regular review
- Updated as your services, client base or risk profile evolves
What do you need to do?
- Review your AML Policies and Procedures
- Ensure they accurately reflect how your practice operates in reality
- Move away from generic wording and tailor documents to your specific risks
