Key takeaways
- Companies House has now confirmed 18 November 2025 as the base date (the Base Date) from which the new identity verification (IDV) requirements will come into force
- From 18 November 2025, new directors will have to verify their identity before incorporation of a new company or their appointment to an existing company, and existing directors will have to confirm their identity within 14 days of the date of the company’s annual confirmation statement.
- Verification can be done directly with Companies House or through an agent that has registered with and been authorised by Companies House as an Authorised Corporate Services Provider (ACSP). Reed Smith is an approved ACSP and can support clients with these new requirements.
Scope of the new verification requirements
Companies House has confirmed that the new identity verification requirements for directors and persons with significant control (PSCs) of UK companies will come into force on the Base Date. These changes were introduced as part of the Economic Crime and Corporate Transparency Act 2023 (ECCTA), which aims to, among other things, deliver a more reliable companies register for businesses and help to prevent fraud. For further guidance on ECCTA, please refer to our previous alert.
The new IDV requirements introduce a mandatory identity verification process for all new and existing individual directors and individual PSCs, who must undertake a verification process to confirm their identity. Upon successful verification, Companies House will issue a personal identity code to the individual. This will be a one-off process, and individuals can use this unique code for each of their appointments to UK entities now and in the future without having to undertake the verification process again.
The new verification requirements will also extend to individual members of limited liability partnerships. Companies House has also confirmed that the new requirements will extend to directors of overseas companies that have a UK establishment.
For now, the verification requirements are limited to individuals. They do not extend to corporate directors, corporate PSCs or corporate members, but Companies House has indicated that they will extend the verification requirement to corporates and officers of corporates at a later date, with details still to be confirmed.
Significance of 18 November 2025
- New directors: Any individuals appointed from the Base Date will need to verify their identity before incorporation of a new company or before their appointment to an existing company.
- New PSCs: PSCs being newly notified to Companies House from the Base Date must verify their identity within 14 days of notification of their PSC status to Companies House.
- Existing directors: Current directors must verify their identity by the date the company files its next annual confirmation statement after the Base Date.
- Existing PSCs: Current PSCs must submit a statement confirming identity verification either within 14 days of the company’s next confirmation statement date after the Base Date (if they are also a director of the company), or within 14 days of the first day of their birth month as shown on Companies House (if they are not also a director of the company) – e.g., if their date of birth is 23 February, the deadline would be 14 days from 1 February.
Options for verification
Individuals can carry out the verification process themselves directly with Companies House. This will require an individual to have a GOV.UK account and may not be convenient for individuals that do not reside in the UK and/or do not have a form of UK biometric ID.
Verification can also be done by an ACSP on an individual’s behalf. An ACSP is an agent that is registered with and authorised by Companies House to make filings on behalf of its clients. Reed Smith is an approved ACSP and provides the verification service for clients.
What next?
Companies House has started writing to companies at their registered email address to inform them and their agents about what their directors and PSCs need to do to comply with the new requirements.
From the Base Date, directors and PSCs will also be able to check the Companies House register to confirm their own identity verification deadlines.
The recommendation is that individuals complete verification as soon as possible to allow for any unplanned delays in the process. The consequences of not complying with the verification requirements by the deadline could include (i) the company being unable to make any further filings at Companies House; (ii) an individual being unable to take office and act in their intended official capacity; (iii) public censure by Companies House; and (iv) possible criminal and civil penalties under ECCTA or disqualification proceedings against individuals.
If you need any further information on these new requirements or if you would like Reed Smith to support you with the verification process, please do not hesitate to get in touch.
Client Alert 2025-218