If you run an accountancy practice in the UK in 2026, your Client Due Diligence obligations are changing faster than at any point since the 2017 Money Laundering Regulations came into force. The latest amendments and supervision changes mean many firms’ existing AML due diligence frameworks are already out of date.
What Has Changed in AML Due Diligence for Accountants
On 25 March 2026, HM Treasury laid The Money Laundering and Terrorist Financing (Amendment) Regulations 2026 before Parliament, with most provisions expected to come into force 21 days after Royal Assent in late June or early July 2026.
For accountants, the key Enhanced Due Diligence requirements include:
- EDD is now focused on unusually complex or unusually large transactions, rather than all complex ones, requiring firms to update their risk assessments and procedures.
- The Trust Registration Service (TRS) now covers more non-UK trusts holding UK land, tightening expectations around verifying beneficial ownership.
- The definition of Trust and Company Service Provider (TCSP) activities has widened, capturing more accountancy practices that sell or support “off-the-shelf” companies.
These changes directly affect how accountancy firms design and apply Client Due Diligence and ongoing monitoring.
The ACSP requirement and CDD
From spring 2026, practices that file accounts or incorporate companies at Companies House must be registered as Authorised Corporate Service Providers (ACSPs) and supervised for AML. ACSPs must carry out identity verification that meets Home Office standards and maintain robust AML due diligence for all relevant clients. Failure to register or comply can result in penalties and restrictions on filing.
The ICAEW has highlighted ACSP registration and updated client due diligence standards as key 2026 priorities for accountants, warning that firms that treat this as an admin exercise are likely to fall short of regulator expectations.
AML supervision shifting to the FCA
The UK Government has confirmed that AML supervision for professional services, including accountancy, will move to the Financial Conduct Authority (FCA) as a single supervisor. This will bring accountancy firms into a more intensive supervisory environment, with a strong focus on how Client Due Diligence and Enhanced Due Diligence requirements work in practice, not just on paper.
The FCA’s expectations around AML due diligence typically include:
- Documented risk-based CDD for each client.
- Clear triggers for Enhanced Due Diligence, including high-risk countries, PEPs, complex ownership, and unusual transaction patterns.
- Evidence that CDD and EDD have been applied consistently and reviewed periodically.
Why many Accountancy firms are exposed
Recent supervisory reviews across the professions have repeatedly found that accountants’ client due diligence files often lack:
- Clear evidence of how identity was verified.
- Documentation of the rationale for risk ratings.
- Adequate source of funds and source of wealth checks where higher risk is present.
- Proper application of Enhanced Due Diligence requirements for PEPs and complex structures.
In practical terms, that means many firms have AML due diligence policies that look credible, but file-level evidence that does not meet the standard regulators now expect.
How Intelect supports robust CDD and EDD
Intelect’s risk assessment platform is designed to help accountancy practices operationalise client due diligence and enhanced due diligence requirements consistently across their client base. It provides:
- Structured CDD workflows aligned with UK AML regulations.
- Risk scoring that reflects client type, geography, services, and behaviour.
- Audit-ready documentation to support regulatory inspections and internal reviews.
Start a free 7-day trial of Intelect’s risk assessment platform no obligation Claim your free trial
Alongside this, EDD‑Pro gives your team a single workspace for actually performing the due diligence behind those risk scores. The platform combines passport and identity verification (including NFC chip and manual entry options) with AI‑powered open‑source searches, sanctions and PEP database checks, adverse media, and clear data visualisation, then packages the findings into a downloadable report with your notes and a complete audit trail. It is designed to be fast, efficient, and integration‑friendly, so accountants, lawyers, and property agents can move from Client Due Diligence to documented decisions without bouncing between multiple systems. Find out more here.
And finally, Intelect’s CPD-certified eLearning focuses on practical AML due diligence skills not just theory.
EDD-Pro members receive at least 50% off all Intelect CPD-certified eLearning. Find out more about Intelect Training
Act now, before the rules bite
With the 2026 AML amendments, ACSP requirements, and FCA supervision all advancing, this is the moment for accountants to upgrade their Client Due diligence and AML Due Diligence frameworks. Waiting until after an inspection or regulatory enquiry is almost always more expensive, in both time and reputation than acting proactively.
