Understanding ECCTA: Compulsory Identity Verification For PSCs

A lot of information has been published recently about the requirement for directors to have their identity verified under the new ECCTA requirements. But the detail relating to persons with significant control (PSCs), who are also subject to compulsory identity verification, is a little more obscure. They are also subject to compulsory identity verification and the timing for that exercise is also underway as from 18 November 2025.

In this latest article in our 'Understanding the Economic Crime and Corporate Transparency Act 2023 (ECCTA)' series, we build on our earlier articles covering directors and LLP members to focus on the requirement for PSCs.

The UK's PSC regime, introduced in 2016, established a framework requiring companies and LLPs to identify PSCs, and notify their details to Companies House. PSCs themselves have been under a legal obligation to notify the company or LLP as soon as they become aware of their status. These measures were designed to increase transparency and combat financial crime.

Previously Companies House did not independently verify PSC information, meaning that the system largely relied on a PSC self-reporting and honesty. ECCTA aims to strengthen the reliability of the Companies House Register by ensuring PSC information is verified, reducing the risk of abuse.

What is identity verification?

The compulsory identity verification (IDV) regime applies to PSCs as well as company directors and LLP members and requires the individuals to verify their identity at Companies House by providing certain personal information and supporting identity documents such as passport or driving licence. Once verified, the individuals receive a unique personal identification code (PIC) from Companies House. This code must be used to link the individual to each company or LLP which they are PSC of, and for future filings and confirmations.

Companies House is moving from being a passive to an active gatekeeper, vetting those who control companies and consequently increasing the reliability of the information that they hold.

A more detailed explanation of how individuals can verify their identity is given in our earlier briefing, Understanding ECCTA: identity verification.

Timing and triggers

As with directors and LLP members covered in earlier articles, PSCs face phased implementation of the compulsory IDV requirements, with specific deadlines depending on whether they are newly appointed or already registered.

The verification requirements became compulsory from 18 November 2025, with phased implementation for existing directors, LLP members and PSCs. The requirements for PSCs (whether of a company or LLP) are as follows:

New PSCs

If a person becomes a PSC after 18 November 2025, the PIC must be supplied at the time the PSC is notified to Companies House.

• On an incorporation and provided the PSC has shared their PIC with the company or LLP, the PIC can be notified on the incorporation form IN01.The company or LLP must confirm that the individual has verified their identity.
• Where a new PSC is being added to an existing company or LLP and again provided the PSC has shared their PIC with the company or LLP, the PIC can be notified on form PSC01 or LLPSC01.Again, the company or LLP must confirm that the individual has verified their identity.
• If the PSC has not shared their PIC, then they will be required to submit the code within 14 days of being listed as a PSC on the register (see Notification below).

Existing PSCs

The process for existing PSCs is slightly more complex,

• Any person who is registered as a PSC and who is also a director must verify their identity and file their PIC within 14 days of the date for filing the first company's confirmation statement due after 18 November 2025.
• Anyone already registered as a PSC but who is not a director must verify their identity and file their PIC within 14 days of the start of the month in which they were born. For example, if their date of birth is 22 January, the 14-day period will begin on 1 January 2026, and the code must be notified by 14 January.

Notification

Notification is done via a new online service at Companies House, either by the PSC themselves or someone on their behalf. Note that there does not appear to be a hard copy form for making the notification. Provided it is made within the deadline, the PSC may use the online service, on up to two occasions, to request a 14 day extension of the time period for notification.

Although IDV only needs to be done once, the PIC needs to be notified for each company or LLP, which will mean using the online service on multiple occasions and at different times.

The details required for notification are, thankfully, quite simple:

• Details such as the individual's name and partial date of birth
• The individual's Companies House PIC
• Details of the company or LLP in relation to which the individual is notifying
• Where required, a reason why the individual's name on the public record does not match the name under which their identity was verified. (This might be, for example, because the person has got married and changed their name since their identity was successfully verified.)

Consequences of non-compliance

If the IDV requirements are not complied with, the individual PSC may be committing an offence and must pay a financial penalty or fine. A note will also be made against the individual's name on the public register.

Relevant legal entities

Companies and LLPs which have a relevant legal entity (RLE) as its PSC will need to designate one of its directors or LLP members as its 'relevant officer', whose identity must be verified. Companies House must be notified of that appointment, and also of any change in the particulars of the relevant officer. The purpose of these provisions is to ensure that there is always a verified individual who is traceable for the RLE. These provisions are not yet in force, they are expected in Spring 2026, but no specific date has been set yet.

Selecting the 'relevant officer' is a further step in closing-off a transparency gap by adding an individual to represent and hold some responsible for corporate RLEs.

Additional investigations regarding PSCs registered details

Also under ECCTA, Companies House has significant new powers to query, investigate and challenge information held on the public register. Where there are doubts about the accuracy or authenticity of information it may formally query the company's position.

We are starting to see Companies House use this proactive power by sending out letters where they believe there may be a discrepancy on the PSC register, asking the company for evidence to substantiate its position as regards the identity of a PSC. Failure to respond within 14 days is a criminal offence and may result in financial penalties or prosecution.

This power supports Companies House's role of being an active gatekeeper, vetting those who control companies and consequently increasing the reliability of the information that they hold.

Read the original article on GowlingWLG.com

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.