ARTICLE
1 December 2025

Company Administration – Mandatory Identity Verification Requirements Now In Force And Companies House Guidance On Enforcement

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Herbert Smith Freehills Kramer LLP

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Identity verification (IDV) is now mandatory for all new and existing directors (of both UK incorporated companies and overseas companies with UK establishments)...
United Kingdom Corporate/Commercial Law
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Identity verification (IDV) is now mandatory for all new and existing directors (of both UK incorporated companies and overseas companies with UK establishments), individuals with significant control (PSCs) and members of LLPs. Companies are also no longer required to maintain certain local statutory registers (see our blog post here for further details).

The changes which came into force on 18 November 2025 were made through amendments to the Companies Act 2006 made by the Economic Crime and Corporate Transparency Act 2023 (ECCTA).

IDV is a two-step process – firstly the individual needs to have their identity verified, which will generate their unique identifier (their Companies House personal code); this personal code then needs to be provided to Companies House to confirm that their identity has been verified.

Companies House has published numerous guides to the new IDV regime which are available on its website, including guidance on how it will approach non-compliance with the IDV requirements. The guidance sets out Companies House's enforcement approach, which includes:

  • informing people of their obligations;
  • 'nudging and guiding' individuals to comply; and
  • taking action for non-compliance (which includes the option to prosecute through the courts, refer to the Insolvency Service and issue financial penalties).

Companies House has also released details of the online service through which PSCs need to provide confirmation of their verified status. This online service can also be used by PSCs to request extensions to the deadline for providing this confirmation.

Companies House has published updated versions of its guidance and its forms to reflect the changes.

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.

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