Get ready for the new mandatory identity verification requirements to be introduced this year

Contributors: Christina Sinclair, Tom Swan

Date published: 7 October 2025

A guide to the new Companies House mandatory identity verification requirements

Companies House has confirmed that the new mandatory identity verification requirements set out in the Economic Crime and Corporate Transparency Act 2023 will go live on 18 November.

This article sets out the new identity verification regime and the options for entities and individuals to meet the new requirements, including the ability to voluntarily arrange for an individual’s identity to be verified before this becomes mandatory.

Who is required to have their identity verified from 18 November?

From 18 November, all new and existing company directors and persons with significant control (PSCs) will be required to have their identities verified. This will initially apply to all UK companies, unregistered companies (for example, companies formed under Royal Charter), and overseas companies with an establishment in the UK.

Limited liability partnerships (LLPs) will also be affected by the change, and regulations have recently been published in relation to this. Identity verification will also apply to individual members of LLPs and their PSCs, in terms broadly mirroring the requirements for companies.

It had been expected that an individual officer of a registrable relevant legal entity would also be required to be verified from 18 November, but Companies House has confirmed that this requirement will be introduced later. (It has not given a specific date.)

What will the new requirements involve for companies that are incorporated after 18 November, and for the appointments of their directors and PSCs?

Directors

From 18 November, it will be mandatory for all directors of a newly incorporated company to have their identities verified in advance of submitting the incorporation documentation to Companies House.

New directors appointed to a company after the implementation date will also need to have their identities verified before notice of their appointment is submitted to Companies House (and in any event, an individual must not act as a director of a company until their identity has been verified).

PSCs

If a person becomes a PSC of a company from 18 November, that person must submit a statement to Companies House confirming that their identity has been verified, together with details of the personal code they will have received at the end of the verification process.

For new companies, this statement will need to be filed within 14 days of the company’s incorporation date; for existing companies, it will need to be filed within 14 days of the date on which notice of the new PSC was filed at Companies House.

What will the new mandatory identity verification requirements involve for existing companies?

For existing companies, the implementation of the new requirements will be phased in over a 12-month period, starting on 18 November.

Directors

For a company that exists on 18 November, all directors of that company will need to arrange for their identities to be verified before the company’s next annual confirmation statement is filed at Companies House.

For overseas companies with a UK establishment, existing directors will need to arrange for their identities to be verified before the next anniversary of the date on which the UK establishment was opened.

PSCs

PSCs of existing companies are required to provide a statement to Companies House confirming that their identities have been verified, together with details of their personal codes.

The period during which this statement must be submitted to Companies House depends on whether a PSC is also a director of the same company.

If a PSC is also a director of the same company

If a person is both a PSC and a director of the same company, the statement and personal code must be submitted to Companies House within 14 days of the date on which the company’s annual confirmation statement is due.

This is separate to the requirement of that person to submit their personal code, in their capacity as a director, as part of the company’s annual confirmation statement.

PSC only

If a person is only a PSC of a company, they will need to submit a statement to Companies House, with details of their personal code, within 14 days of the first day of their birth month.

What are the implications for people who are a director and/or a PSC of several companies?

Companies House has confirmed that, from 18 November, directors and PSCs will be able to check the Companies House register to confirm the due dates for identity verification for all their current roles. Identity verification will only need to be done once, but must be in place before the earliest of those dates.

Once a person has had their identity verified, they will receive a personal code. Companies House will use that personal code for all relevant roles held by that person.

To prevent fraudulent use, an individual’s personal code should only be shared with people they trust – for example, those filing documents at Companies House on their behalf, or on the company’s behalf.

Can I voluntarily arrange to have my identity verified before 18 November?

Yes. In recognition of the fact that there are more than six million people currently falling within scope of the regime, since April 2025 Companies House has allowed individuals to voluntarily verify their identity.

Companies House is encouraging individuals to consider arranging for their identities to be verified as early as possible.

Is this a new annual requirement or a one-off?

This is not a new annual requirement. In most cases, identity verification will be a one-off, and individuals will only need to arrange for their identity to be re-verified if Companies House directs them to do so.

How can an individual’s identity be verified?

Identity verification can either be completed directly through the GOV.UK One Login Service or, alternatively, indirectly through an Authorised Corporate Service Provider (ACSP). To provide this service, ACSPs will need to be authorised by Companies House. Broadly, an ACSP can be a regulated individual or organisation that is supervised for anti-money laundering purposes, such as a law firm or accountancy firm.

How will direct identity verification via GOV.UK One Login work?

Companies House launched its service for direct identity verification in April 2025. It is free to use.

Three services are available. Individuals will be directed to the most appropriate option, depending on what identity verification documents they can provide, and the device they are using.

Companies House has provided guidance on each of the services.

An Impact Assessment published in 2024 estimates that 94.5% of officers falling within scope of the identity verification requirements will be ‘easy to verify’, and should be able to be verified using the GOV.UK One Login service. The other 5.5% – classified as ‘harder to verify’ – are, for example, overseas residents with certain types of biometric passports, or with non-biometric passports.

How will ACSPs provide indirect identity verification?

ACSPs have been able to provide an identity verification service since April 2025. Unlike with the GOV.UK ID check, which is free of charge, it is likely that ACSPs will charge a fee.

Broadly, an ACSP will undertake the necessary identification checks in accordance with rules and guidance, and will confirm to Companies House once this verification is complete.

What identity documents should to be provided to an ACSP will depend on the identity documentation available, and whether the ACSP can use identity document validation technology.

Generally, it is expected that most individuals will use the free GOV.UK One Login services, but for those unable to do so (for example, those falling within the ‘harder to verify’ category) using an ACSP may be the best way to comply with the new requirements.

Will further identity verification requirements be introduced?

Yes. The identity verification of UK directors, LLP members, and PSCs is the first phase in a broader package of identity verification requirements.

In spring 2026, it is expected that a person delivering documents to Companies House on behalf of an entity (for example, a company secretary or an employee) will also need to have their identity verified.

While the current measures are aimed at directors, individuals in an ‘equivalent’ role to a director will also eventually be required to have their identities verified. This includes general partners of limited partnerships, corporate members of LLPs and, as noted above, individual officers of registrable relevant legal entities.

What should I do now?

As it may take some time for all relevant individuals to complete the verification process, and this will require some action to be taken by the individuals themselves rather than someone on their behalf, companies should carefully consider encouraging early verification before it becomes mandatory. This is especially true if any relevant individual will be unable to use the GOV.UK ID checks for any reason.

If you require further information on this or another related matter, please do get in touch with our Corporate Finance team.

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