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On November 18, 2025, significant new identity verification (IDV) requirements come into force for all individuals who are, or become, directors, members of limited liability partnerships (LLPs), and people with significant control (PSCs) of UK-registered entities. These changes are designed to improve corporate transparency and prevent economic crime. The new rules will affect both UK-based and overseas individuals involved in UK companies and LLPs.
Who is affected?
The new IDV requirements apply to all new and existing:
- directors of UK companies
- members of UK LLPs
- PSCs of UK companies and LLPs
- directors of overseas companies that have a UK establishment.
For the time being, IDV requirements only apply to individuals. No announcement has yet been made about when the verification requirements for registrable relevant legal entities (RLEs) (being legal entities that would be an individual with significant control were they an individual) to inform Companies House of their relevant officer and confirm that their identity is verified will come into force. Mandatory IDV requirements for relevant individuals within limited partnerships, corporate directors and corporate LLP members are also expected to commence at a later (as yet unspecified) date.
What are the new requirements?
From November 18:
New directors: A newly appointed director must have their identity verified before they can act in that capacity and before their appointment is notified to Companies House. Companies must ensure that no unverified individual acts as a director.
New LLP members: Individuals who become members of an LLP will be required to verify their identity and provide their personal code to Companies House and will not be able to act as an LLP member until they have done so.
New PSCs: An individual must submit their personal code to Companies House within 14 days of being listed as a PSC.
Existing directors: There will be a 12-month transition period for existing companies to comply. During this period, existing directors must verify their identity and provide their personal code when the company's next confirmation statement is due. Individuals with more than one directorship will be required to do this for each company of which they are a director although they will only need to verify their identity once and subsequently provide their personal code for each company's confirmation statement when due.
Existing LLP members: Existing individual members of LLPs must verify their identity and provide their personal code when the LLP's next confirmation statement is due.
Existing PSCs: Existing PSCs will also need to verify their identity during the transition period, the timeframe for which varies according to whether they are also a director of the same company as follows:
- PSCs who are also directors—these individuals will need to provide their personal code separately for each role. As a PSC, it must be submitted to Companies House in the company's first confirmation statement filed after November 18.
- PSCs only—the personal code must be provided within 14 days of the first day of an individual's birth month after November 18. For example, where an individual's birthday is January 17, the 14-day period would start on January 1 and end on January 14.
Directors and PSCs will be able to check the Companies House register to see the IDV due dates for all their roles from November 18. Failure to verify within the required timeframes may constitute a criminal offence for both the individual in question and the company and every other officer in default.
Overseas companies: On the opening of a UK establishment, an overseas company must confirm that its directors have had their identity verified and must do the same whenever a new director is appointed. For overseas companies that already have a UK establishment registered at Companies House, the transition period is linked to the anniversary of the overseas company's registration document.
What are the IDV routes available?
There are two routes for IDV:
1. Direct verification with Companies House
Using the GOV.UK ID One Login (via an app or by answering security questions online) or by entering details from a photo ID on GOV.UK One Login and attending a Post Office (for those with UK ID documents or biometric evidence).
2. Indirect verification via an Authorised Corporate Service Provider (ACSP)
Verification can be completed through an ACSP, which may include an identity interview.
Applicants must provide:
- required personal information (such as their full name, date of birth and nationality)
- required evidence (i.e. government-issued ID)
- required contact information (such as an address and email).
For indirect verification, the ACSP must be satisfied that the information and evidence provided are true before submitting a verification statement to Companies House.
IDV is expected to be a one-off process unless Companies House has reason to believe the information provided is false or misleading, in which case re-verification may be required.
What else is changing?
Along with the IDV changes, the Companies Act 2006 will be amended so that the ability for companies to maintain their own statutory registers of directors and secretaries, for LLPs to maintain their own statutory register of members, and for companies and LLPs to maintain their own statutory registers of PSCs will be abolished. This will be replaced with a requirement to file specified information at Companies House. However, existing companies may want to ensure that any historical registers are kept accessible for future reference.
Private companies will no longer have the option to use the central register to record information about their members. The effect will be that all companies will be required to maintain their own register of members.
Next year, IDV will also become compulsory for all individuals presenting information to Companies House, making it a requirement for filing any document.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
