The mandatory identity verification for companies requirements set out in the Economic Crime and Corporate Transparency Act 2023 (ECCTA) will go live this year.
These measures aim to:
improve corporate transparency, which is a central tenet of ECCTA;
prevent the use of nominee arrangements and opaque corporate structures to hide company control; and
improve the reliability and accuracy of the records maintained by Companies House.
This article will help both companies and individuals prepare for these changes and set out the options to meet the new identity verification requirements, including the ability to voluntarily arrange for an individual’s identity to be verified from 8 April 2025.
Who is required to have their identity verified in 2025?
In autumn 2025, new mandatory identity verification requirements will be introduced for:
all new and existing UK directors;
persons with significant control (PSCs) (broadly, an individual who holds 25% or more of the voting rights or shares in a company, or who otherwise exercises significant control of it); and
an individual officer of a registrable relevant legal entity (RRLE).
Registrable relevant legal entities (RRLE)s should consider closely which individual is most appropriate to be notified as its registerable officer. In situations where companies form part of a group, it may be worth considering the notification of an individual who has been appointed as a director to most or all of the group companies. You will find our brief explainer on what qualifies as an RRLE at the end of this guide.
While not yet confirmed, it is expected that the identity verification requirements from autumn 2025 will also apply to members of limited liability partnerships (LLPs) and their PSCs/RRLEs.
When will the mandatory identity verification requirements be introduced?
The outline transition plan published by Companies House states that the new mandatory identification requirements should be introduced by autumn 2025. However, there is not yet a firm timetable for their implementation.
After the implementation date, what will the new mandatory identity verification requirements involve for new companies which are incorporated after that date and the appointments of their directors?
Directors
From the implementation date, 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 appointments are 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
PSCs and relevant officers of RRLEs have more flexibility. They can arrange for their identities to be verified either in advance of an incorporation or within a short, specified timeframe after the incorporation has taken place in accordance with the terms of a notice to be provided to them from Companies House. This initial period will be 14 days (from the date of the notice) for PSCs, and 28 days for RRLEs, although Companies House can extend this period.
What will the new mandatory identity verification requirements involve for existing companies?
There will be a phased approach to the implementation of the new identity verification requirements for existing companies.
For a company which exists on the implementation date, all directors, PSCs, and officers of RRLEs of that company will need to arrange for their identities to be verified before the company’s first annual confirmation statement is filed after the implementation date.
Can I voluntarily arrange to have my identity verified before autumn 2025?
Yes. In recognition of the fact that there are more than 6 million people currently falling within scope of the regime, Companies House has allowed individuals to voluntarily verify their identity from 8 April 2025.
Is this a new annual requirement and will I need to reverify my identity periodically?
No, this is not a new annual requirement. Subject to a limited number of exceptions, identity verification will be a one-off requirement, and individuals will only need to arrange for their identity to be reverified if Companies House directs them to do so.
I’m a director of several companies. Do I need to arrange for my identity to verified for each company?
No. Once a person has had their identity verified, they will receive a unique identifier number from Companies House (UID). This UID can be used for each company to which a director is appointed.
UIDs will be required for the filing of confirmation statements and for other filings, including notice of a new director appointment.
To prevent fraudulent use, an individual’s UID 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.
How can an individual’s identity be verified?
There are two ways to do this:
directly through the GOV.UK One Login services; or
indirectly through an Authorised Corporate Service Provider (ACSP) (broadly, a regulated individual or organisation supervised for anti-money purposes (such as a law firm or accountancy firm) and who has been authorised by Companies House to provide this service).
How will direct identity verification via GOV.UK One Login work?
On 8 April 2025, Companies House launched its ‘Verify your identity for Companies House’ service at GOV.UK One Login. This service is free of charge to use.
Three services are available, and individuals will be directed to the most appropriate option, depending on the identity verification documents they can provide, and the device they are using.
GOV.UK ID Check app
Individuals can use the GOV.UK ID Check app if they have a phone with the required specifications (including a camera) and any of the following documents:
Biometric passport from any country
UK photo driving licence (full or provisional)
UK biometric residence permit (BRP)
UK biometric residence card (BRC)
UK Frontier Worker permit (FWP)
Companies House has confirmed that it is acceptable to use an expired BRP up to 18 months after its date of expiry. Otherwise, to use the app, the relevant identity document must not have expired.
GOV.UK ID Check – online digital verification
An individual’s identity can be verified answering a number of security questions about, for example, their mobile phone contract, credit cards or any bank accounts.
If individuals have one of the following types of photo ID, they can verify themselves online with GOV.UK:
UK passport
UK photocard driving licence (full or provisional)
Individual’s will also need:
a UK bank or building society account; and
a UK National Insurance Number.
Rules published in relation to the identity verification process by Companies House state that this service can be used with a UK passport which is up to six months expired. Otherwise, to use online digital verification, the relevant identity documents must not have expired.
GOV.UK ID Check – in person at Post Office
Persons who live in the UK can also use an in-person assisted verification service.
To use this service, an individual will need to submit details of their available photo ID on GOV.UK One Login, and will be asked to select a local Post-Office branch (offering in-branch verification). Individuals will then need to go to the selected Post Office, in person, where they will scan the individual’s photo ID and will take a photo of the individual.
A person will need to have one of the following types of photo ID to use this service:
biometric passport from any country;
non-biometric passport (for supported countries);
UK photocard driving licence (full or provisional);
European Union (EU) photocard driving licence (full or provisional);
UK biometric residence permit; or
biometric national identity photo card from an EU country, Norway, Iceland, or Liechtenstein.
They will also need a current UK residential address.
The rules for this service provide that a passport, or a UK biometric residence permit, can be up to 18 months expired. Otherwise, to use Post Office verification, the individual’s identity documents must not have expired.
Companies House has provided guidance on each of the three services available with GOV.UK One Login.
The Impact Assessment published in 2024 suggests that the vast majority (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, with only 5.5% being classified as ‘hard to verify’ (such as, for example, overseas residents with non-biometric passports or certain biometric passports).
Indirect identity verification via an Authorised Corporate Service Provider (ACSP)
ACSPs have been able to provide an identity verification service since 8 April 2025. Unlike the GOV.UK ID check service which is free of charge, it is likely that a fee will be charged by an ACSP for providing this service.
Broadly, an ACSP will undertake the necessary identification checks in accordance with the rules and guidance, and will confirm to Companies House once this verification is complete.
The identity documents 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 ‘hard to verify’ category noted in the Impact Assessment referred to above), using an ACSP may be the best available route to comply with the new verification requirements.
Will further identity verification requirements be introduced?
Yes. The identity verification of UK directors and PSCs is the first phase to be delivered of 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 be required to have their identities verified.
As mentioned above, the verification requirements will extend to members of LLPs. In addition, they will also eventually apply to general partners of limited partnerships and are expected to apply to overseas companies which have a UK establishment registered at Companies House.
We will provide further updates on these subsequent phases once there are clearer implementation dates.
What should I do now?
As it may take some time for all relevant individuals to complete the verification process, and this is likely to require some action to be taken by the individuals themselves rather than someone on their behalf, companies should carefully consider undertaking early verification for them before it becomes mandatory.
This is especially the case if any relevant individual will be unable to use the GOV.UK ID checks referred to above (for example because they are resident overseas and do not have a biometric passport).
The timetable for the introduction of the mandatory identity verification requirements is relatively fluid, and we will provide a further update once the implementation date is confirmed.
If you require further information on this or another related matter, please do get in touch with our corporate finance team.
What is a registrable relevant legal entity?Broadly, an RRLE is a legal entity that would have been a PSC had it been an individual, and which is subject to its own disclosure requirements. This includes UK companies and companies that have voting shares admitted to trading on a regulated market in the UK or EEA, or on certain other prescribed markets. RRLEs must identify a relevant officer, verify their identity and to maintain that verified status. This is to ensure that there is one officer with their identity verified who is traceable for each RRLE. Relevant officers are defined in the Companies Act as:
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