Edward Craft
- Partner
- Corporate
The implementation of compulsory identity verification: Autumn 2025
Following on from our previous article on ID Verification and Authorised Corporate Service Provider registration, the decade-long process to update company law processes is entering a new phase with the implementation of compulsory identity verification (“ID-V“) for key individuals involved in UK corporate entities from 18 November 2025 under the Economic Crime and Corporate Transparency Act 2023 (“ECCTA“).
Who needs to verify?
The ID-V regime will apply to all new and existing company directors (modified for other registered business vehicles), PSCs and anyone filing on behalf of UK companies.
The aim of targeting these key individuals is to improve and protect the integrity of the data on the register as part of the ongoing battle against organised economic crime.
Key timelines
The implementation of the ID-V regime will be phased and the key timelines include:
- From 8 April 2025, individuals have been able to verify their identity voluntarily.
- From 18 November 2025, verification will become compulsory for new incorporations and appointments (this means that all new directors must verify their identity before incorporation or appointment, and all PSCs must verify their identity within 14 days of incorporation or registration (or 28 days for a relevant officer of an RLE).
- From 18 November 2025, a 12 month implementation period begins for existing directors and PSCs to verify their identity ahead of the next confirmation statement.
- By Spring/ Summer 2026 (specific date TBC), only verified individuals or ACSPs will be able to make filings at Companies House.
- By the end of 2026, enforcement will begin for non-compliance/ failure to identify.
How to verify: direct and indirect identity verification
Voluntary ID-V is now available. There are two routes to verification:
- Direct verification
Individuals can verify their identity directly with Companies House online (including via an app or browser). In addition, for those without access to the internet or necessary documentation, in-person verification will be available at designated UK Post Office branches, albeit use of this service will be rare.
The process of verifying your identity directly with Companies House is free of charge and relatively straightforward, but requires a biometric passport, UK driving licence or other approved forms of identity documentation.
- Indirect verification via an Authorised Corporate Service Provider (“ACSP”)
Alternatively, individuals may verify their identity through an ACSP which may agree to do so. To become an ACSP the intermediary needs to be registered with a competent anti-money laundering supervisory body.
Once registered, ACSPs can carry out ID-V on behalf of individuals. However, to do so, it will be necessary to follow the internal policies and procedures of the ACSP and also ensure that legal requirements are satisfied and appropriate documentation presented. An ACSP is verifying that the person is the person in the identity documents, not simply certifying that a copy is a true copy.
What happens when you verify?
Once an individual has successfully verified their identity, they will be provided with a Companies House personal code, which must be retained and will be required to file documents at Companies House, to be appointed as a director or registered as a person with significant control and will need to be added onto confirmations statements.
Individuals should keep their personal code secure and only share it with trusted advisors who file on their behalf.
Failure to verify
The failure to verify identity when required to do so could result in various consequences, including:
- criminal proceedings may be commenced with the potential of an unlimited fine;
- civil penalties issued by the Registrar of Companies;
- a director will be prohibited from acting as a director;
- applications to register a new company being rejected by the Registrar;
- being unable to make statutory filings; and
- marking an individual’s status as “unverified” on the public register. One can also expect that credit institutions will have policies to withdraw lending from borrowers with “unverified” persons involved with it.
Practical takeaways
Companies should prepare for the implementation of compulsory ID-V now and not wait until the 2025-2026 confirmation statement becomes overdue. To ensure compliance, companies should:
- identify and communicate to every individual who will require ID-V of the new requirements (and ensuring that these individuals have appropriate, current and accessible identity documents);
- determine whether direct or indirect (ACSP) verification is most appropriate (if the former, ask that those individuals set up the relevant online login accounts, or, if the latter, engage with registered ACSPs);
- encouraging early ID-V ahead of the 18 November 2025 start date (early verification helps avoid delays, resolve issues and ensures compliance); and
- develop internal procedures for storing and managing Companies House personal codes securely.
From 18 November 2025, all company directors and PSCs will be required to include their personal code on the company’s next confirmation statement. This requirement is mandatory and failure to comply will prevent the company from filings its confirmation statement.
We therefore recommend that company directors and PSCs check when their company’s next confirmation statement is due and ensure that they have completed their ID-V in good time. The process is not complicated, but for companies and groups with multiple directors and PSCs, it will become an administrative challenge if left to the last minute.
Meet the team:
Enea Aniaj
- Solicitor
- Corporate
