ID Verification and Authorised Corporate Service Provider registration
The UK Government continues its mission to tackle economic crime with the introduction of compulsory identity verification (“ID-V“) requirements for directors and people with significant control of companies incorporated in any part of the UK which are expected to come into force in Autumn 2025. New companies will need ID-V on incorporation but existing companies will require it over a twelve month period in line with the confirmation statement cycle.
As part of these reforms, all new and existing company directors (modified for other registered business vehicles), PSCs and anyone filing on behalf of a company must verify their identity, the objective of which is to improve and protect the integrity of the data on the register as part of the ongoing battle against organised economic crime.
Direct and indirect identity verification
If a person wishes to verify their identity directly with Companies House, they can do this online (including via an app or browser) or face-to-face, which will require a visit to a post office, further particulars of which are available at The Registrar’s (Identity Verification by the Registrar) Rules 2025.
Alternatively, a person may wish to verify their identity indirectly through an Authorised Corporate Service Provider (“ACSP“). From 25 February 2025, appropriate intermediaries (such as company formation agents, solicitors and accountants) that are also registered with a competent supervisory body in the UK for the purposes of anti-money laundering compliance will be able to apply to become registered as an ACSP with Companies House. Once registered, the ACSP can carry out identity verification services. However, Companies House will have the power to suspend an ACSP where it has cause to believe that a person is not “fit and proper” to carry out the functions of an ACSP.
Transition period
There will undoubtedly be a transition period for individuals to verify their identity with Companies House, which should provide individuals and organisations with sufficient time to comply with the new requirements.
New directors, for example, must verify their identity before an application for the formation of a company is made, and post-incorporation, a director must verify their identity as soon as possible and before their appointment is notified to Companies House.
The relevant officer of existing RLEs will have 28 days to verify their identity, whereas individual PSCs will have 14 days of registering with Companies House.
Consequences of failing to verify identity
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;
- marking an individual’s status as “unverified” on the public register; and
- one can also expect that banks will resolve not to lend to “unverified” persons, accelerating compliance over the next twelve months.
Practical takeaways
Companies must start thinking about who needs to have their identity verified and ensure that they have appropriate identity documents readily available and may also wish to think about whether these individuals will verify their identity indirectly through an ACSP. Whilst an ACSP which works with the client may have access to the identity documents as part of their KYC and AML requirements, those documents cannot be used for ID-V purposes without relevant consents because they have been taken for different purposes. In addition, the identity documents are unlikely to be sufficiently current so anticipate 2025 becoming the year when your passport is produced more than ever, but without the joys of actually going on holiday.