The new identity verification rules are now live: what you need to do

With the ID-V requirements now live, companies must act promptly to ensure certain individuals are verified on Companies House before confirmation statements can be submitted. This article lays out the practical steps to follow so you, your company, directors and persons with significant control (PSCs) can stay compliant.

Practical checklist for compliance with ID-V:

• Identify all individuals requiring ID-V: Compile a list of your company’s directors, PSCs, LLP members, and anyone else who will be filing forms on the company’s behalf (including any Authorised Corporate Service Providers (ACSP)). These key individuals must be verified. Note that there are different duties for directors and PSCs.
• Update your filing procedures: Revise internal processes so that no Companies House filing is made without considering ID-V. For example, for the next confirmation statement, add a step to confirm that all directors are verified and have provided their codes (and similarly, confirm PSC verification if applicable): this is particularly important for group companies where individuals may hold multiple roles. If you use a filing software or an external company secretarial service, consult them about how they will incorporate the personal code requirement. Software providers may be updating their systems to include fields for these codes. Ensure that before filing the confirmation statement, all current officers have ID-V codes on file; if not, pause and obtain the codes.
• Review your corporate structure: The ID-V rules present an opportunity to review your corporate structure. If you have any dormant companies or very old entities that add little strategic value, consider dissolving them or consolidating roles to streamline governance. Restructuring now can reduce the administrative burden of ID-V and simplify future filings. Note Companies House fees continue to increase.
• Double-check Companies House communications: Ensure your company is receiving Companies House updates about ID-V. As of March 2024, every company was required to provide a registered email address to Companies House. Make sure the email on record is active and monitored (for example, if you used an adviser’s email, see that they forward you any notices). Companies House is sending out email reminders with key dates and will continue to do so.
• Plan for new appointments: Build ID-V into your onboarding process for new directors or LLP members. Inform prospective appointees that they must verify their identity via GOV.UK One Login as a prerequisite. Consider providing internal guidance to assist them through the process and avoid delays in registering appointments. We have briefly outlined the direct and ACSP routes in our article here.
• Monitor ongoing compliance: Assign responsibility within your organisation for tracking ID-V status and deadlines. Regularly review your compliance position to ensure no filings are delayed due to outstanding verifications.

We previously explored the background to these Companies House reforms in our article on ID-V.

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