What ICAEW's 2026 deadline briefing means for Gulf directors

ICAEW's January 2026 briefing covers three things: identity verification deadlines, AML supervision changes, and Companies House filing requirements. It's written for UK accountants. Here's our read for Gulf directors.

On identity verification: the 12-month transition period runs from November 2025 to November 2026. But the deadline isn't the same for everyone. Your personal deadline is when your company's next confirmation statement falls due. If your company was incorporated in June, your deadline is June 2026 — not the end of November. This catches Gulf directors who assume they have until the last possible moment.

On AML supervision: this change affects accountants, not directly directors. But it affects you indirectly. From spring 2026, any accountant filing on your behalf must be registered as an ACSP. If your current UK accountant isn't ACSP-registered, they will not legally be able to submit filings for you — including your annual accounts and confirmation statement. Fileminder is ACSP-registered. If you're unsure whether your current accountant is, ask them directly.

On confirmation statements: the fee is now £34. Small — but missing it triggers a £500 penalty and, if persistent, strike-off proceedings. The ICAEW article notes that Companies House has been more active in initiating strike-off for non-compliant companies. For Gulf directors whose companies are dormant or lightly traded, this is a particular risk — it's easy to assume nothing needs filing when trading is minimal.

The bigger picture: 2026 is not a distant deadline. If your company was incorporated between now and October, your verification deadline could arrive before the end of this year.