Verify your identity with Companies House ahead of the deadline - Gilson Gray

Verify your identity with Companies House ahead of the deadline

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Verify your identity with Companies House ahead of the deadline
Findlay Anderson

Directors -Verify your identity with Companies House ahead of the deadline – 18 November 2025

What is changing?

From 18 November 2025, it becomes mandatory to verify the identity of directors and persons with significant control (PSCs) on Companies House. Companies may no longer rely on internal declarations or minimal checks. Instead individual directors and shareholders must evidence their own identity.

Why are the changes being introduced?

The requirement was introduced by the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023) to strengthen the integrity of Companies House register and to tackle economic crime. The new identity and verification (ID&V) requirements came into place to combat fraud and to improve data quality and transparency in order to make the companies register more trustworthy, with the aim to enhance business confidence and growth through a more reliable register.

Who is affected by the change?

It is estimated that about 7 million people are affected by the change. People who need to provide ID&V to Companies House are:

  • All new and existing directors of UK companies.
  • All new and existing persons with significant control (PSCs) of UK companies.
  • All new and existing directors of overseas companies with a UK branch.
  • All new and existing Members of a Limited Liability Partnership (LLP).
  • Persons who file documents on behalf of companies (e.g. third-party agents).
  • Officers of a Relevant Legal Entity (RLE).
When do the new rules apply?
  • 8 April 2025: The voluntary identity-verification service became available allowing individuals to verify prior to the mandatory phase. It is therefore possible to start the verification process today.
  • 18 November 2025: Mandatory identity verification begins for new directors, new PSCs, new LLP Members and overseas company directors.
  • Up to18 November 2026: The 12-month transition period for existing directors, PSCs and LLP members. The deadline will vary from entity to entity, but individuals must complete verification ahead of this deadline.
  • Further phases to bring in other types of legal persons will follow at a later date.

It is important that companies and individuals mark their own company’s confirmation-statement date because that triggers the deadline for existing directors. For PSCs, the deadline to register is linked to the date they were appointed.

How does a director provide ID&V to Companies House?

There are two ways to ID&V; directly with Companies House or by using an Authorised Corporate Service Provider (ACSP). Companies House will only accept UK and foreign passports, driving licenses and some other national ID cards. An ACSP can accept a broader range of documents, but the specific requirements of an ACSP can vary and must be discussed with the individual ACSP.

Practical considerations before you start the process:
  • Ensure you have an email address that is unique to you and cannot have been used by anyone else verifying themselves at Companies House
  • You must evidence your full name, date of birth and address (if you have lived at your current address for less than 12 months, more than one address will need to be verified).
Verifying directly with Companies House:
  • Go to Companies House and use the GOV.UK One Login (the process may require the download of an app to your phone)
  • You will be able to upload a picture of your photographic identification document and it may involve a face scan or questions to carry on a further credit check.
  • Once you have submitted the information you will be issued with an 11 digit personal code. Make sure to document the code in case any errors appear.
  • A successful ID&V result means your code will be displayed in your ‘Manage Accounts’ section of your Companies House account. Make sure you keep your personal code secure, you will require it in the future for any filing purposes.

In some circumstances the Post Office can aid with verification of photographic ID in combination with the online process. This is for example if you are using a non-biometric passport. You will get directed by the online login to attend a Post Office.

Verifying using an ACSP:
  • An ACSP will act on your behalf to verify your identity with Companies House. They can accept a broader range of documents (every ACSP will have their own requirements), but still need to evidence your full name, date of birth and address.
  • If using an ACSP, you should be aware that the personal code will still be sent to you on the email address you provided to the ACSP.
 What are the requirements for a PSC?

A PSC will ID&V in the same manner as a director, although it needs to be submitted through a different service for each entity. Different timelines to directors also apply for PSCs.

  • If an individual becomes a PSC after 18 November 2025, they have 14 days to verify themselves with Companies House from the date they registered as a PSC with Companies House.
  • If the individual is already a PSC on 18 November 2025 and a director of the company, their verification must be done within 14 days of the Confirmation Statement being submitted.
  • If the individual is already a PSC on 18 November 2025 but not a director of the company, their 14 days period starts from the first day of their month of birth registered on Companies House i.e. if the date of birth is 22 January, the 14 day period starts on 1st

Please note that if you are a director and a PSC, two separate notifications must be submitted to Companies House.

What must the legal entity do?

Companies House will not automatically link the ID&V of an individual to every legal entity they are involved in. It falls upon the entity to update Companies House. Every legal entity should therefore start to compile a list of all those they need to obtain ID&V from and ensure they inform the individuals and update the register in good time before submission of their Confirmation Statement.

Entities should also keep a record of all those in the entity who need to verify and when the verification was carried out. Each individual only needs to carry out verification once, but verification must be submitted for each entity an individual is linked with on Companies House.

What are the consequences of not providing ID&V?
  • The relevant entity will be marked as ‘unverified’ on Companies House which can affect the credibility of the business. It may affect business opportunities with investors, lenders and suppliers.
  • Entities will not be able to file their Confirmation Statement if their directors have not been verified.
  • Failure to verify may constitute a criminal offence if the entity has not taken reasonable steps to comply.
  • Enforcement may involve the issue of fines or the striking-off of directors.

Please note that for PSCs who are not directors, the law is more nuanced in relation to the company’s criminal liability for non-compliance of verification, but the PSC themselves may commit a criminal offence. The company should record that they have notified the PSC to verify themselves.

Tips to avoid problems
  • Timing: Act early. If you wait until the last minute, you will likely rush the process, could make mistakes and may encounter queueing or technical difficulties.
  • Matching your details: The verification process will compare your official ID with the details registered with Companies House. Ensure you compare the details for any mistakes to ensure there is no delay or rejection in the process.
  • Technical issues with Companies House: Technical issues have been reported by early uses, therefore it is recommended to verify as soon as possible to ensure technical problems can be resolved.

View our full Corporate service offering here.

Mjria Barton
Trainee Solicitor, Corporate  
Phone:01224 011 692
Email:  MBarton@gilsongray.co.uk

 

Findlay Anderson
Partner, Head of Corporate
Phone:01224 011 692
Email:  fanderson@gilsongray.co.uk

The information and opinions contained in this blog are for information only.  They are not intended to constitute advice and should not be relied upon or considered as a replacement for advice.  Before acting on any information contained in this blog, please seek solicitor’s advice from Gilson Gray.

Findlay Anderson's portait
Findlay Anderson
Partner, Head of Corporate

Findlay is a Partner in our Corporate / Energy team. With over 20 years’ experience in the Energy / Oil & Gas industry and 14 years in international in-house “Head of Legal / General Counsel” positions, Findlay has a wealth of experience advising on a vast array of issues impacting business globally and locally.

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