All directors of UK companies, as well as people with significant control (PSCs), are subject to new mandatory identity verification (IDV) requirements at Companies House. Other individuals will be impacted later this year.
The IDV requirements, introduced by the Economic Crime and Corporate Transparency Act 2023 (ECCTA), took effect on 18 November 2025 for individuals who are directors of UK companies (or overseas companies with a registered UK establishment), PSCs or members of UK LLPs.
In particular, all new directors, whether appointed on incorporation or to an existing company, must now have their identity verified upon appointment. A transition period applies to existing directors, linked to the company’s confirmation statement date.
While this new requirement may be seen as an irritant by busy directors, the regime has teeth and needs to be taken seriously.
Identity will usually only need to be verified once, regardless of how many directorships you hold. Once it has been completed, you will receive a personal code from Companies House – make sure you keep this safe, as will be needed to confirm IDV on future filings.
IDV requirements will be extended later (the date is still to be confirmed) for corporate directors, corporate members of LLPs, relevant legal entities, and general partners of limited partnerships – these will all need to nominate an officer who must have their identity verified.
Restrictions will also be introduced on who can file information at Companies House – and many will need to have their identity verified to do so.
Directors
The IDV requirements apply to all directors of UK companies, with a transition period for directors appointed prior to 18 November 2025.
-
New company formation: all proposed directors must verify their identify before the application to register the company can be made.
-
New appointments: all new directors must verify their identity before their appointment is filed at Companies House and, more importantly, before they act as a director.
-
Existing directors (as at 18 November 2025): Under the transition period, companies will need to confirm in their next confirmation statement that all their directors have had their identity verified, by providing their personal codes.
Individuals are prohibited from acting as a director if their identity has not been verified (unless exempt). Acting in breach of this does not affect the validity of their acts as a director. But in practice, the prohibition means that a director should not act on behalf of a company in their capacity as a director until their identity has been verified, not least because it’s a criminal offence and fines may be payable.
In addition, a failure by a director to verify their identity could delay the filing of the company's annual confirmation statement, subjecting the company to a late filing financial penalty.
Companies also have a duty to ensure that individuals do not act as directors unless their identity has been verified. Breach could lead to fines for the company and its directors.
The IDV requirement also applies to directors of overseas companies with a UK establishment registered at Companies House. These directors must not act as a director of the company in respect of the affairs of the company’s UK establishment unless their identity is verified.
PSCs and RLEs
Registrable PSCs, in relation to companies or LLPs, must also verify their identity:
-
On incorporation: Proposed persons with initial significant control must verify their identity either before or after incorporation. If the application for incorporation does not confirm their identity has been verified, Companies House will send a notice to the PSC, requiring them to confirm their identity has been verified within 14 days.
-
Becoming a PSC: When a company files details of a confirmed PSC to Companies House, it can opt to confirm the PSC's identity has been verified, by providing the PSC's personal code. If this code is not given, Companies House will send a notice to the PSC, requiring them to confirm their identity has been verified within 14 days.
-
Existing registered PSCs (as at 18 November 2025): Under the transitional provisions, all registered PSCs must confirm their identity has been verified by providing their personal code to Companies House using the online service for this purpose. The required time frame depends on whether the individual is also a director of the company.
A PSC who is also a director must provide their IDV personal code separately for each role: as a director, in the company’s confirmation statement, and as a PSC, using the separate online service within 14 days of the company’s confirmation statement date. If the PSC is not a director of the same company, they must confirm their identity has been verified within the first 14 days of their birth month. For example, if their date of birth is 22 January, the relevant 14 day period will begin on 1 January 2026.
To use the online service, you’ll need to sign in (or create sign in details) and provide the company number and your IDV personal code. This can also be done by someone on your behalf.
IDV requirements will take effect at a later date for registrable relevant legal entities (RLEs), who will need to nominate an individual director as a ‘relevant officer’ and confirm that person’s identity has been verified.
Breach of these requirements by a PSC or RLE is an offence, punishable with a fine. Companies do not, though, have a duty to ensure compliance by the PSC or RLE. Informing beneficial owners of the new requirements though is usually sensible.
LLP members
At present, the IDV requirements only apply to LLP members who are individuals. It is expected they will take effect for corporate members of LLPs later in 2026.
All LLP members who are individuals must confirm their identity is verified upon becoming a member.
On registration of a new LLP, proposed members who are individuals must verify their identity before the application for registration.
Under the transitional provisions, existing LLP members who are individuals must verify their identity before the LLP’s next confirmation statement is filed, as their personal codes will be required.
People filing at Companies House
IDV requirements will also be introduced for people filing documents at Companies House, as well as restrictions on who can make filings. It is anticipated these changes will take effect from November 2026.
Under these presenter restrictions which are aimed at addressing identity fraud, individuals filing documents at Companies House on behalf of a company will only be able to do so if they are an officer or employee of that company and have verified their identity (unless they are an ACSP or an employee or officer of an ACSP or an exception applies).
An individual will not be able to file a document on their own behalf, or on behalf of another individual, unless their identity is verified (or employee or officer of an ACSP).
Advisers will not be able to file on behalf of a company unless they are registered as an ACSP.
Under the current form of the legislation, employees will not be able to file on behalf of other group companies, unless they are a director or company secretary of those companies. It is hoped that legislative changes will be made to enable group employees to do so, to avoid the administrative difficulties which the current framework is likely to cause large groups.
In the meantime, groups should review their current filing practices and ascertain the impact of this restriction on the group companies’ continued ability to file. Using an ACSP for filings can help with this issue.
Limited partnerships
Alongside new disclosure requirements for limited partnerships, which are expected to take effect later in 2026, a general partner which is a legal entity will need to specify an individual managing officer to act as its 'registered officer’. That registered officer will need to verify their identify.
Limited partnerships will also need to file an annual confirmation statement (through an ACSP).
It is anticipated that this IDV requirement will take effect later in 2026 and that existing general partners will have a transition period within which to comply.
How to verify identity
There are two routes available for verifying your identity:
-
Direct verification with Companies House.
-
Verification by an AML-regulated intermediary which is registered with Companies House as an ‘authorised corporate service provider’ (ACSP).
Winston Taylor International LLP is registered as an ACSP and can offer an IDV service to existing clients.
Both routes require checking the individual against specified identity documents. The permitted documents slightly differ between the two routes. A biometric passport will usually be the easiest option, whether using an ACSP or the direct verification route.
The Companies House direct verification route has three options, each of which allows slightly different documents to be provided as evidence of identity:
-
GOV.UK One Login app: permitted documents include a biometric passport, UK photocard driving licence, and UK biometric residence card or permit. A smartphone with a working camera is needed.
-
GOV.UK One Login web service: permitted documents include a UK passport, UK photocard driving licence, and UK bank or building society current account and national insurance number. This also asks some security questions (usually on your financial history, such as mobile phone contracts, mortgages, loans, or credit cards).
-
Face to face service (at a selected post office which offers 'in branch verification’): permitted documents include a biometric passport, non-biometric passport from selected countries, and UK or EU photocard driving licence, but this service is only available to those with a UK home address. The appointment must be booked online using the GOV.UK One Login website.
If using an ACSP, a wider list of documents is permitted and for the usual preferred route includes:
-
a biometric or machine-readable passport
-
UK, Isle of Man, Channel Islands or EU photocard driving licence
-
EU or EEA biometric identity card
-
UK biometric residence card or permit.
There is also another route for ACSPs, with a longer list of options, under which two documents must be provided.
Non-UK resident individuals who do not have a suitable biometric passport available for the GOV.UK One Login service, or are reluctant to use the UK government portal, will need to use the services of an ACSP.
Whether using the GOV.UK One Login service or an ACSP, you will need to provide an email address which has not previously been used by anyone else for IDV. If you have multiple directorships, consider which would be the most appropriate email address to use. It is possible to change the email address later through your account.
Your name (and any former name), date of birth and residential home address (and previous home address if you have moved home in the last 12 months) must also be provided.
Additional documents will usually need to be provided if you have moved home in the last 12 months (such as utility bills) or changed your name (such as a marriage certificate).
When is identity verification completed?
Individuals are prohibited from acting as a director until their identity has been verified. It is, therefore, very important to know when IDV has been completed. This will often be highly relevant where board meetings are held shortly after board changes on a corporate acquisition.
If a person verifies their identity directly with Companies House, they are treated as having their identity verified from the date of the Companies House confirmation.
If identity is verified by an ACSP, the ACSP will file a verification statement at Companies House. Identity will be treated as verified from the date on which this statement is filed.
After IDV has been completed, the individual will receive a 'unique identifier’ (a personal code) from Companies House. This needs to be kept safely. Individuals will need to provide this personal code in future filings at Companies House for each new directorship, LLP membership or PSC registration. For existing directorships, it will need to be included in the company’s next confirmation statement to confirm identity has been verified. Over the course of the transition period, it will therefore link multiple directorships to the one individual, and improve the quality of information on the public register.
Liability
Failure to comply with the IDV requirements is an offence and could give rise to unlimited fines for the individual (and in some cases the company) or a financial penalty from Companies House.
If the lack of IDV delays the company in filing its confirmation statement, the company may have to pay a financial penalty for late filing.
Companies House will annotate the public register when the required identity verification is complete for a directorship. Equally, if you have failed to verify your identity on time, Companies House will also display a note to this effect.
In addition, it is a criminal offence to provide misleading, false or deceptive information to Companies House 'without reasonable excuse’, punishable with fines. There is also a new aggravated criminal offence for knowingly providing misleading, false or deceptive information, punishable with fines and potentially imprisonment. Both offences could be triggered by a false statement made to Companies House in relation to IDV.
Also, if coupled with two or more other company legislation breaches in a five year period, the director could also risk disqualification.
The IDV requirements do, therefore, need to be taken seriously.
Practical steps for IDV
-
Identify everyone in your organisation who will need their identity verified and explain the requirements to them. We can assist with this.
-
Check when your company’s next confirmation statement is due, especially if there are multiple UK companies in the group, so the IDV deadlines can be prepared for well in advance.
-
Everyone affected should check they have suitable identity documents easily available. If any passport renewals are imminent, it may be sensible to verify identity first.
-
If board appointments are planned, (for example, upon a proposed corporate acquisition) verify the proposed directors’ identity in advance to ensure they can act as directors immediately upon their appointment taking effect.
-
Groups with a number of UK companies should review their current filing practices against the proposed new restrictions on filing at Companies House (which are expected to take effect in November 2026), and identify whether any changes are needed as well as which employees will need to verify their identity.
-
Make sure a suitable email address is used. Companies House will send the individual’s personal code to this address. It cannot be an address which has been used by someone else for IDV (so group email addresses are not appropriate).
-
Personal codes should be kept safe by each individual and shared with the company secretary (or other person who deals with the Companies House filings) so that they can be included in future filings.
Unfortunately, it is not possible to link all a person’s directorships in one go or even in advance – the personal code must be provided for each company’s confirmation statement at the relevant time.
-
Any director who is also a PSC will need to provide their IDV details for their PSC registration separately, using the online Companies House service. This can be done by someone else on their behalf.
-
Check that the details for each director have been correctly stated on the Companies House register. Allow sufficient time for correcting any differences.
For more information on the impact of ECCTA on directors more widely, please see our article 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.
[View Source]