Companies House third-party code of conduct: what agents must do

Companies House published a third-party code of conduct on 28 October 2026. It sets the behaviour Companies House expects from everyone who deals with it, including accountants and agents who phone, email or visit for clients. It is about how you treat Companies House staff, not how you file, and breaking it can lead to Companies House ending calls or blocking contact.

What is the Companies House third-party code of conduct?

The code is a short policy paper setting out standards of behaviour for third parties. Companies House says it “will not tolerate bullying, harassment, discrimination, victimisation, intimidation, abuse, violence or threatening behaviour”. It also says it takes all reasonable steps to prevent harassment of its staff, including by third parties, in line with its legal obligations.

The full code has six short sections. It carries only one date, its publication on 28 October 2026.

Does it apply to accountants and agents?

Yes. The code applies to all third parties who engage with Companies House. Its list includes customers, members of the public, suppliers, consultants, service providers, contractors, agency workers, visitors and external partners.

The code does not name “agents” or “presenters” as a group. An accountant filing for a client or calling about a rejected document is still a customer or service provider dealing with Companies House, so the code covers them.

It applies to every channel:

• face-to-face contact
• telephone calls
• letters and emails
• online interactions
• meetings, events and training, on or off Companies House premises

What behaviour does the code expect?

Companies House expects third parties to:

• treat others with dignity, respect, courtesy and professionalism
• communicate respectfully and respect personal boundaries and privacy
• act honestly and responsibly
• follow security requirements and reasonable instructions

The code calls respect “a two-way responsibility”. Companies House says it expects its own staff to treat third parties the same way.

What counts as unacceptable behaviour?

Unacceptable behaviour can be verbal, physical, written or online. The code gives these examples:

• offensive, insulting or derogatory comments, jokes or gestures
• unwanted sexual comments, attention or contact
• aggressive, abusive, intimidating or threatening behaviour
• inappropriate behaviour linked to a protected characteristic under the Equality Act 2010
• deliberately excluding, humiliating or undermining someone

Behaviour does not need to be intended to cause offence or harm to be unacceptable. A frustrated call about a filing deadline can cross the line if it becomes abusive.

What can Companies House do if the code is broken?

Companies House will take “appropriate and proportionate action”. The code lists these options:

1. end an interaction or meeting
2. ask someone to leave the premises
3. restrict future access
4. limit or block communication
5. raise the matter with the person’s employer
6. take contractual action
7. report serious incidents to the police or another authority

The list is not exhaustive. For agents, being blocked from contact or reported to your employer would make it harder to sort out clients’ filings.

Why has Companies House published it now?

The code arrived two days before a new employer duty took effect. SI 2026/1065 brought sections 20 to 22 of the Employment Rights Act 2025 into force on 30 October 2026. Section 21 makes employers liable if they fail to take all reasonable steps to prevent third parties harassing their staff.

The code itself does not name the 2025 Act. It refers only to Companies House’s legal obligations and the Equality Act 2010. So the link is our reading of the timing, not a statement by Companies House.

How is this different from ACSP duties?

The code governs conduct towards staff. The legal duties of a Companies House authorised agent are separate.

Being an ACSP sets out those legal duties. See our guide to ACSP registration for accountants, and compare HMRC’s standard for agents, which also expects courteous dealings with HMRC staff.

What agents should do now

1. Share the code with staff who call, email or visit Companies House.
2. Plan for busy periods. ID verification queries and confirmation statements will raise pressure around the ID verification deadline.
3. Escalate through formal routes rather than in heated calls. The code itself does not cover complaints about Companies House.
4. Check your own firm’s policy. The same 30 October 2026 duty applies to your firm as an employer, so clients must not harass your staff. Business.gov.uk’s guide to third-party harassment links to EHRC and Acas guidance. See also the Employment Rights Act timeline.

Frequently asked questions

When did Companies House publish its third-party code of conduct?

On 28 October 2026, as a policy paper on GOV.UK.

Does the code change how I file documents at Companies House?

No. It covers behaviour towards Companies House staff, not filing rules or ACSP duties.

Can Companies House stop dealing with an agent who is abusive?

Yes. The code says it may end an interaction, limit or block communication, restrict access or raise the matter with the person’s employer.

Does unintended rudeness break the code?

It can. The code says behaviour does not need to be intended to cause offence or harm to be unacceptable.

Is the code linked to the Employment Rights Act 2025?

The code does not say so. It came out two days before the Act’s third-party harassment duty started on 30 October 2026.