Companies House identity verification: what directors and PSCs must do

Identity verification under the Economic Crime and Corporate Transparency Act 2023 became compulsory on 18 November 2025. Over the twelve months from that date, every existing director and person with significant control (PSC) has to verify, and every new one has to verify before appointment. This note covers who must verify, the two ways of doing it, and what happens if it is not done.

Who has to verify

• Directors of UK companies, including directors of dormant companies and of companies that have never traded.
• Individual PSCs, whether or not they are also directors.
• Where a PSC is itself a company (a relevant legal entity), a relevant officer of that entity, who verifies on its behalf.
• Members of LLPs, under parallel rules.
• Companies House has said that in due course only verified individuals and authorised agents will be able to file documents at all, so people who file on a company’s behalf will need to verify too.

The requirement attaches to the person, not to the company. A director of six companies verifies once and uses the same personal code for all six.

The deadlines

New appointments. A person appointed as a director on or after 18 November 2025 must verify before the appointment is notified. The appointment form asks for the personal code, and an appointment without one is rejected. On incorporation, every proposed director and PSC must be verified before the company can be formed.

Existing directors. The deadline is the date of the company’s next confirmation statement falling after 18 November 2025. The confirmation statement now includes a statement that the directors have verified, and it cannot be filed without it. A company whose confirmation date fell in December 2025 has already passed its deadline; one with an October date has weeks left.

Existing PSCs. A PSC who is also a director follows the director deadline. A PSC who is not a director has a separate deadline, tied to the start of the company’s confirmation period rather than to its end, so it will not match the director deadline. Check the exact date for each person rather than assuming one date covers everyone.

The two routes

Route one is directly with Companies House through GOV.UK One Login. You create or sign in to a One Login account, then prove who you are with a passport, a UK driving licence or certain other identity documents, usually by scanning the document and taking a photograph on a phone. If the document check fails, or you have no suitable document, there is an in-person option at a Post Office. Once verified, Companies House issues a personal code. This route is free.

Route two is through an Authorised Corporate Service Provider (ACSP). An ACSP is a firm supervised for anti-money laundering purposes, such as an accountancy practice, a law firm or a formation agent, that has registered with Companies House and undertaken to carry out identity checks to the required standard. The ACSP checks your documents, submits a verification statement to Companies House, and you receive a personal code in the same way. This route suits people living abroad and people whose documents do not work well with an automated check.

Whichever route you use, the outcome is the same personal code, and verification is done once. The code is private. You give it to the company, or to the agent who files for it, so it can be included on the confirmation statement and on appointment forms. It should not be published or shared more widely than that.

Connecting the code to the record

Verifying is step one. Step two is linking the personal code to each directorship and PSC record, through Companies House’s online service or by the company’s agent when the confirmation statement is filed. A director who has verified but whose code has never been attached to the company’s record is, as far as the register is concerned, still unverified. For a group, that means one code attached to every company in the group. Our confirmation statement work now includes checking that every officer’s code is in place before the statement is filed.

What happens if you do not

• It is an offence to act as a director without having verified once the requirement applies to you, and the company and every officer in default can also be liable. Companies House has the power to impose financial penalties directly, without going to court.
• Appointments of unverified directors are rejected, so a board change stalls until the person has verified.
• The confirmation statement cannot be filed. That brings late filing consequences of its own and, if it continues, the possibility of the company being struck off.
• Companies House can annotate the public register to show that a director has not verified. Banks, lenders, customers and anyone else who searches the company can see it.

None of these is dramatic on day one. They accumulate, and they surface at the worst moment: a bank account opening, a property completion, a tender, a sale.

Overseas directors and shareholders

Directors and PSCs living outside the UK can use One Login where the service can read their passport. Where it cannot, or where the automated check fails, the ACSP route is usually the practical answer, with documents certified and checked to the required standard. Our work for overseas-owned UK companies covers this alongside the registered office and the filings the owner cannot do remotely.

What to do this month

1. List every director and PSC across every company you are involved with, with the confirmation statement date for each.
2. Verify, by whichever route suits you, well before the earliest date on the list.
3. Attach the personal code to each record, and keep the code with the company’s other statutory information.
4. Build verification into the appointment process, so a new director is verified before the board minute is signed. Our director, PSC and secretary changes work now starts with that step.
5. Check the register once the confirmation statement has been filed.

We guide directors and PSCs through the identity verification requirements as part of our company secretarial work, including the awkward cases: non-UK documents, name changes, and directors who verified but never connected the code.

If you are not sure whether you and your fellow directors have completed the process, or the confirmation statement date is close, we offer a 30-minute call at no charge to go through the list with you.