Companies House has announced that identity verification (IDV) will be mandatory for all new and existing directors and persons with significant control (PSCs) from 18 November 2025.
Background to the IDV requirements
IDV requirements are part of the changes to UK company law and administration being introduced by the Economic Crime and Corporate Transparency Act 2023 (ECCTA). The ECCTA received Royal Assent in October 2023 and is being implemented in phases. To date, there have been three significant commencement dates:
- 4 March 2024: Companies House was given new powers in relation to querying information submitted for filing and companies required to provide Companies House with a registered email address and an annual 'lawful purposes' confirmation;
- 2 May 2024: Companies House was given the power to issue financial penalties for most breaches of the Companies Act 2006, as an alternative to commencing court proceedings; and
- 1 September 2025: the new strict liability corporate offence of failure to prevent fraud came into effect (see item 4 below for more details).
You can read more about the changes being made by the ECCTA on our corporate notes blog here.
The IDV requirements
The IDV requirements will apply to all new and existing directors (and equivalents for other entities), PSCs and those filing information with Companies House. The IDV process can be carried out by Companies House or via an authorised corporate service provider (ACSP). Details of the process are set out in The Registrar (Identity Verification and Authorised Corporate Service Providers) Regulations 2025, made in January 2025, and in the Companies House rules, published in February 2025 (read more on our corporate notes blog here and here).
Companies House has also published the following guidance on the new IDV requirements:
- verifying your identity for Companies House; and
- when you need to verify your identity for Companies House.
On completion of the verification process, individuals will be allocated a personal Companies House code – a unique identifier which can then be used to confirm that the verification process has been completed. Companies House has issued guidance on the use of these codes, which confirms that the same code will be used for every directorship a person holds and sets out what to do in the event that a personal code has been compromised or shared without consent.
IDV expected to become mandatory from 18 November 2025
Voluntary IDV has been possible since April 2025 (read more on our corporate notes blog here). Companies House has announced that the plan is that from 18 November 2025 the requirements will be mandatory and from that date:
- any individual being appointed as a director, either on incorporation or as a new director of an existing company, will need to confirm that their identity has been verified as part of the incorporation/appointment process;
- companies will need to confirm that each of their directors have verified their identity when filing the company's first annual confirmation statement which falls due after 18 November 2025;
- any individual being registered as a PSC will have to confirm that they have verified their identity within a 14-day period starting on the date of their PSC registration;
- any individual already registered as a PSC who is also a director of the company will have to confirm that they have verified their identity within a 14-day period starting on the date on which the first annual confirmation statement by the company is due after 18 November 2025; and
- any individual already registered as a PSC of a company who is not also a director of the company will have to confirm that they have verified their identity within a 14‑day period starting from the first day of their month of birth – for example if their date of birth is 16 April 1974, the 14-day period will start on 1 April 2026.
Companies, and their directors and PSCs, should plan ahead now because, assuming the relevant provisions of the ECCTA are commenced as planned from 18 November 2025, it will not be possible to incorporate a company or file a confirmation statement unless all of the directors of the company have had their identity verified. A commencement order bringing the relevant ECCTA provisions into force is expected to be laid before Parliament shortly.
The mandatory IDV requirements for individual members of LLPs are also expected to start from 18 November 2025. Companies House has confirmed, however, that the IDV requirements for limited partnerships, corporate members of LLPs, corporate directors of companies and officers of corporate PSCs will be brought into force at a later date.
For more details on IDV, see our snapshot here.
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.
