Companies House Changes: Identity Verification from 18 November 2025

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From 18 November 2025, company directors, Limited Liability Partnership (LLP) members and people with significant control (PSCs) will be required to verify their identity with Companies House. These reforms, introduced as part of the Economic Crime and Corporate Transparency Act 2023, are intended to make it harder to register false information and to strengthen the reliability of the public register.

Contents

• Introduction
• Who Needs to Verify?
• Implementation – Key Dates
• New Requirements from 18 November 2025
• How Can You Verify Your Identity?
• Personal Codes
• Reverification
• What Happens If You Do Not Verify?
• Conclusion

Introduction

The Economic Crime and Corporate Transparency Act 2023 represents one of the most significant reforms to UK company law in recent years. A central part of the changes is the introduction of mandatory identity verification (IDV). Initially, the new verification requirements will apply to company directors, members of limited liability partnerships (LLPs), people with significant control (PSCs) and someone who files for a company, for example, a company secretary. Further changes are expected for limited partnerships, corporate directors and corporate LLP members in the near future.

At its core, IDV is the process of confirming that a person is who they claim to be. The aim of this reform is to reduce the risk of false or fraudulent information being added to the public register, particularly in the form of fictitious directors or shareholders.

The first phase of the new regime takes effect on 18 November 2025. Not every detail has yet been finalised, but businesses should be planning ahead now.

Who Needs to Verify?

The new rules cover a wide range of roles connected with UK companies and LLPs. Identity verification will be required for:

• all existing and newly appointed directors of UK companies
• all existing and new individual LLP members, and for each corporate LLP member, a nominated director
• all existing and new people with significant control (PSCs) of a company or LLP
• any relevant officer of a relevant legal entity (RLE), otherwise known as a corporate PSC
• a nominated director of each corporate general partner of a limited partnership
• anyone filing information at Companies House, whether for themselves or on behalf of another person

The same obligations will also apply to directors of overseas companies that have a UK establishment registered at Companies House. While the timetable for compliance is aligned with UK companies, transitional rules will apply for existing overseas directors.

Implementation – Key Dates

The introduction of identity verification is being phased in over the following proposed stages:

• 8 April 2025 – a voluntary identity verification service for individuals was launched.
• 18 November 2025 – verification becomes mandatory for directors, LLP members and PSCs when a new company or LLP is formed, or when a new appointment is made. From this date, a 12-month transition period also begins for existing directors, LLP members and PSCs to complete the process.
• By Spring 2026 – the obligation will extend to anyone filing documents at Companies House. At this point, third parties filing on behalf of a company will need to be registered as an Authorised Corporate Service Provider (ACSP).
• By the end of 2026 – the 12-month transition period will end, and Companies House will begin compliance checks.

Companies House has confirmed that the requirements for limited partnerships, corporate directors of companies, corporate members of LLPs and officers of corporate PSCs will not start on 18 November 2025. These groups will come into scope at a later, as yet unspecified, date.

New Requirements from 18 November 2025

From 18 November 2025, identity verification becomes compulsory for directors, LLP members and PSCs whenever a new company or LLP is incorporated, or when new appointments are made to existing entities. At that point:

• Directors and LLP members will need to provide their Personal Code as part of the incorporation or appointments process. This code is issued by Companies House after completing IDV.
• Anyone becoming a PSC after this date will need to provide their personal code within 14 days of being added to the Companies House register.

Transition Period – Existing Individuals

For existing directors, LLP members and PSCs at 18 November 2025, a 12-month transition period applies. The deadline to complete IDV will vary depending on the role:

• Existing directors and LLP members – verification must be completed at the same time as the company or LLP files its next confirmation statement.
• Existing PSCs – the deadline depends on their circumstances:
• Where a person is both a director and a PSC of the same entity, they must provide their personal code separately for each role. As a director, the code must be included in the confirmation statement; as a PSC, the code must be filed using a separate service within 14 days of the confirmation statement date. The same approach is expected to apply where someone is both a director and PSC of an LLP.
• Where a person is a PSC but not a director/LLP member, they must verify within the first 14 days of their birth month as shown on the Companies House register. For example, if the date of birth is 18 March, the 14-day period begins on 1 March 2026.

Overseas Companies

For overseas companies:

• IDV of individual directors must be confirmed on registration of a new UK establishment, or when a new director is appointed.
• Existing directors must complete IDV by the first anniversary of the opening of the UK establishment after 18 November 2025, regardless of whether they are directly involved in the UK business.

Multiple Roles

Where an individual has more than one role, or is involved in more than one company or LLP, they may need to provide their personal code more than once. Different deadlines may apply, and verification must be completed by the earliest relevant date.

From 18 November, Companies House will allow directors, LLP members and PSCs to view their verification deadlines for all roles via the public register.

How Can You Verify Your Identity?

There are two ways to complete identity verification:

1. Directly with Companies House – this is a free service.
2. Through an Authorised Corporate Service Provider (ACSP) – for example, an accountant or solicitor registered with Companies House, who may charge a fee for the service.

The route chosen determines which identity documents can be used. In some cases, an individual may not be able to verify directly with Companies House if they cannot provide the specific forms of ID required.

Direct Verification - Companies House

If you verify your identity directly with Companies House, there are three different methods available:

1. GOV.UK One Login Check app
• Accepted ID: biometric passport (not expired), UK photocard driving licence (full or provisional), UK biometric residence permit (up to 18 months expired), UK biometric residence card, or a UK Frontier Worker permit.
• This requires a smartphone with a working camera and the GOV.UK app installed.
2. GOV.UK One Login web service
• Accepted ID: UK passport (up to six months expired), UK photocard driving licence (full or provisional), or a UK bank account with National Insurance number.
• In addition to document checks, applicants will need to answer a number of security questions.
3. Face-to-face service (selected Post Offices)
• Accepted ID: biometric passport (up to 18 months expired), non-biometric passport from selected countries (up to 18 months expired), UK or EU photocard driving licence (full or provisional), UK biometric residence permit (up to 18 months expired), and biometric EEA national identity photocard.
• Applicants must also have a UK home address. The process is initiated via GOV.UK One Login, but the final step is completed in person at a selected Post Office.

ACSP Verification

Verification can also be completed through an Authorised Corporate Service Provider (ACSP), such as an accountant or solicitor. This option allows a wider range of identity documents to be accepted, although the exact requirements will depend on the process and technology used.

• Where cryptographic features can be validated, one of the following may be used: biometric or machine-readable passport or Irish passport card (up to six months expired); UK, Isle of Man, Channel Islands or EU photocard driving licence (full or provisional); EU or EEA biometric identity card; UK biometric residence permit (up to 18 months expired) or UK biometric residence card; and UK Frontier Worker permit.
• Where cryptographic features cannot be validated by the ACSP, two separate documents from a specified list will be required — one of which must be photographic. For individuals living outside the UK, at least one must be a government-issued document.

Once verification has been completed, the ACSP provides a verification statement to Companies House. This statement includes the individual’s details, the type of documents used for verification, and supporting information such as reference numbers, expiry dates and issuing countries. Copies of the documents themselves are retained by the ACSP but are not submitted to Companies House.

As our firm is a registered ACSP, we can complete the identity verification process on your behalf and provide the necessary information to Companies House.

Personal Codes

Once identity verification has been completed, Companies House will issue an 11-character personal code. This code is unique to each individual and is used to link their verified identity to the roles they hold on the register.

The personal code is not made public and should be stored securely.

• If verification is carried out through an ACSP, the individual will receive their code by email.
• If verification is completed directly with Companies House, the code will appear on screen once the process is finished. Individuals are advised to store a copy of the code safely, once issued.

The code can also be viewed in the “manage account” section of a Companies House online account. This will need to be provided whenever the individual acts in a role that requires verification — for example, as a director, PSC, or LLP member.

Reverification

In most cases, identity verification only needs to be completed once. Companies House has confirmed that individuals should not attempt to verify again unless specifically instructed to do so.

Reverification may be required if Companies House has reasonable grounds to believe that the information or evidence originally provided was false, misleading or deceptive. In that situation, a notice will be issued to the individual setting out a timeframe in which the reverification must be completed.

By contrast, reverification will not normally be triggered simply because identity documents have expired or been replaced. It is also not expected to be necessary in the event of a change of name, although Companies House has not yet confirmed the process in those circumstances.

What Happens If You Do Not Verify?

Once identity verification becomes mandatory, the consequences of failing to comply are significant.

• Criminal offences and penalties – non-compliance may result in a fine or financial penalty, and Companies House will record on the register that an individual’s identity is not verified.
• Unverified directors – if someone acts as a director without verification, both the individual and the company (along with its directors) will be committing an offence, unless an exemption applies. A director could also face disqualification. Importantly, however, the validity of their appointment or any decisions made will not be invalid simply because verification has not taken place.
• Unverified PSCs – a person who is, or was at the relevant time, a PSC but does not complete IDV will also be committing an offence.

From a practical perspective, failure to complete verification will prevent the company from making key submissions at Companies House.

• A director or LLP member who has not been verified cannot be registered on incorporation of a new company or LLP.
• An unverified individual will not be able to make filings on behalf of the company once the new filing rules are in force.
• Any new director appointed after 18 November 2025 must complete IDV before the notice of appointment can be filed and before they are able to act. In practice, verification will need to be completed in advance of the appointment to avoid delays.

Preparing in Advance

Although the first obligations take effect from 18 November 2025, it will be sensible for companies to prepare early. Recommended steps include:

• reviewing and, if necessary, updating existing filings for directors and PSCs to ensure the public records are accurate;
• identifying all individuals who will need to complete IDV and briefing them on the new requirements;
• checking whether any individuals may need to use the Post Office service or ACSP route, and reviewing the validity of their ID documents;
• planning around confirmation statement dates, particularly for groups, to ensure verification is completed in time;
• for each individual PSC, identifying the relevant date by which verification must be confirmed; and
• where appropriate, completing IDV on a voluntary basis before the rules become compulsory.

Conclusion

The introduction of mandatory identity verification represents a significant shift in UK company law and the way information is managed on the public register at Companies House. From 18 November 2025, directors, LLP members and PSCs will not be able to complete essential filings unless their identity has been verified.

While the rules are still being phased in, companies should not leave preparations until the last minute. Reviewing company records, briefing affected individuals, and checking the validity of identification documents now will reduce the risk of delays when the new requirements take effect.

With demand for verification expected to rise sharply in the months ahead, starting the process early is the best way to ensure filings remain on track and companies stay compliant.

If you’d like tailored advice on how the new identity verification rules could affect you, contact us today to arrange a free initial consultation. We’ll guide you through the requirements and help you remain compliant under the new verification rules.

This article provides general information and should not be considered professional advice. It reflects legislation and practices at the time of writing, which may change. Individual circumstances vary, so please consult us before taking any action. We accept no responsibility for financial loss arising from actions taken without our written advice.

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AUTHOR

Liam O'Riordan

As Principal at Veritas ATS, I help start-ups, owner-managed businesses, and individuals simplify accounting and tax, providing clear, practical solutions tailored to their needs.

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