Mandatory ID verification for directors and PSCs
From 18 November 2025, ID verification will become mandatory for directors and PSCs - see our recent client alert.
It is important to note that an individual will be prohibited from acting as a director unless their ID has been verified. Breach is an offence for the individual, the company and every officer in default.
ID verification requirements for people who file at Companies House, general partners of limited partnerships, relevant officers of corporate members of LLPs and relevant officers of RLEs will be introduced at a later date.
Affected individuals can verify their ID either directly with Companies House or through an Authorised Corporate Services Provider (ACSP). Reed Smith is an ACSP and can support clients with these requirements.
Disqualification of directors for breaches of company legislation
ECCTA makes amendments to the Company Directors Disqualification Act 1986 to create additional grounds for the disqualification of a director for persistent breaches of companies legislation. This includes expanding the current “three strikes and you’re out” rule, so that the three relevant defaults taken into account when examining a director’s conduct over the previous five years also include circumstances where a financial penalty has been imposed on the director for breaches of the relevant provisions of the companies legislation.
Prohibition on acting unless directorship notified
If notice of the appointment of a person as a director is not filed within 14 days at Companies House, the person may not act as a director until notice has been given. Breach is an offence for those concerned. Companies should therefore ensure that board changes are promptly notified to Companies House without delay.
Company registers
The requirement to maintain local registers of directors, directors’ residential addresses, secretaries and PSCs will be removed from 18 November 2025. Companies will instead be subject to enhanced reporting obligations requiring the information that would have been kept in those registers to be notified to Companies House directly. Although no longer a requirement, companies may consider it good practice to continue to maintain these local registers for their own records and as a basis for reporting to Companies House.
LLPs
Key changes in effect from 18 November 2025 for LLPs include:
- ID verification: the extension of these requirements to LLPs, so that all individual members of an LLP must verify their ID, together with the registrable individual PSCs of an LLP;
- Non-compliance: a prohibition on being a member of an LLP if the person has not been ID verified or notified to Companies House, or is disqualified from acting as a director under the directors’ disqualification legislation;
- Registers of members and PSCs: the replacement of the obligation on an LLP to maintain its own registers of members, members’ residential addresses and PSCs with a single obligation on the LLP to notify this information and any changes to Companies House.
Overseas companies with a UK establishment
ID verification requirements for UK-focused directors of overseas companies with a UK establishment registered at Companies House also begin on 18 November 2025. For existing registered overseas companies, there is a transition period beginning on that date and ending on the next anniversary of the date the UK establishment was opened for the company to deliver a statement to Companies House confirming that its relevant directors have verified their IDs.
If you need further information on these requirements, please do not hesitate to get in touch.
Client Alert 2025-276
