As part of the Economic Crime and Corporate Transparency Act 2023, new ID verification requirements (IDV) are introduced for company directors, members of limited liability partnerships (“LLPs”), people with significant control (“PSCs”) and those making files at Companies House. Limited partnerships are also undergoing changes.
Verifying an individual’s identity (“IDV”) is the process of verifying their identity. In order to reduce the risk of fraud, the IDV regime makes it more difficult to register fictitious directors and beneficial owners and aims to improve the integrity and accuracy of the public record at Companies House.
Certain aspects of the IDV process will become mandatory on 18 November 2025, however, other aspects have not yet been finalised. Whatever the case may be, early preparation is essential. Below are a few of the key requirements.
Who will be verified?
New IDV requirements will apply to:
- Directors of UK companies, both new and existing;
- A nominated director for each corporate member and all new and existing individual members of an LLP;
- All new and existing PSCs of a company or limited liability company;
- Individuals who are relevant officers of a registrable relevant legal entity (“RLE”) (also referred to as corporate PSCs);
- In the case of a limited partnership, each corporate general partner shall nominate a director;
- Those who file information with Companies House, whether on their own behalf or on behalf of others.
The new IDV requirements will also apply to individual directors of foreign companies that are registered with Companies House as having an establishment in the UK. During the implementation phase, the timing of the implementation will be the same as for UK-based companies, but with specific transitional provisions that will apply to directors of overseas companies who are already in place.
Implementation timeline
According to the current proposal, the timeline will be as follows:
8 April 2025 – voluntary IDVs for individuals
18 November 2025 – Incorporation and new appointments will require IDV for directors, members of LLPs, and PSCs. Existing directors, LLP members, and PSCs will also be subject to a 12-month transition period
Spring 2026 – IDV will become mandatory for those who file documents with Companies House. Third parties who file on behalf of a company must register as authorised corporate service providers (“ACSPs”);
End of 2026 – The 12-month transition period will end in 2026 and Companies House will begin to conduct compliance checks.
It has been confirmed by Companies House that the requirement for IDV for limited partnerships, corporate directors, corporate members of LLPs and officers of corporate PSCs will not be implemented on 18 November 2025, but at a later date (which has not yet been determined).
Key contacts
An individual with more than one role or involvement in more than one company or limited liability partnership may be required to provide their personal code to Companies House more than once and may be subject to different deadlines.
The use of IDV will become mandatory from 18 November 2025 for directors, LLP members and PSCs in connection with the registration of new companies and LLPs as well as the appointment of new directors and LLP members to existing companies and LLPs. As part of the registration or appointment process, directors and LLP members will be required to provide the Companies House personal code they receive after completing IDV. As of 18 November 2025, anyone becoming a PSC must provide their personal code within 14 days of being added to the Companies House register.
The transition period for existing directors, LLP members, and PSCs is 12 months. Timings vary according to the role:
- If a company or LLP files its next annual confirmation statement after 18 November 2025, each director and member of the LLP must provide a personal code.
- Existing PSCs will be required to verify their identity by the following date within a year of 18 November 2025:
- A person who is both a director and a PSC of the same company will be required to provide their personal code separately for each role. The director must provide the code in the company’s confirmation statement. In their capacity as a PSC, they are required to provide the code to Companies House within 14 days of the date of the company’s confirmation statement. If a person is both a director and PSC of the same LLP, this is presumed to apply as well;
- A PSC who is not a director of the same company (or LLP) must provide their personal code within 14 days of the month of their birth as listed on the Companies House register. For example, in the case of a person who was born on 22 January, the 14-day period will commence on 1 January 2026.
The IDV of individual directors of overseas companies must be verified at the time of registration of a new UK establishment and each time a new director is appointed thereafter. Upon opening the UK establishment after 18 November 2025, the IDV of existing directors must be confirmed by the first anniversary of the establishment. The principle applies regardless of whether the directors registered at Companies House are involved in the UK business.
The individual may be required to provide their personal code to Companies House more than once if they have more than one role or are involved in more than one business or limited liability partnership. In order to meet the first deadline, the IDV must be completed by that date. From 18 November, directors, LLP members, and PSCs will be able to view the due date for all identity verifications in the Companies House register.
How can you verify your identity?
There are two routes to complete IDV:
- Directly with Companies House, free of charge; or
- The ACSP will determine the fee (to be determined by the ACSP in question).
The type of identification documents required depends on the route selected. Direct verification with Companies House will not be available to individuals who are unable to provide the required form of identification.
Companies House
It is possible to obtain IDV through Companies House in three different ways:
- Using the UK One Login Check app, the following forms of identity are accepted: (i) biometric passport (not expired);
- UK photocard driving license (full or provisional);
- UK biometric residence permits (up to 18 months expired) or UK biometric residence cards; and
- UK Frontier Worker permits. The applicant will need to access a suitable smart phone with a working camera and download the app.
- UK One Login web service .
- Face to face service at selected post offices.
The following forms of identification may be used:
- UK passports (up to six months expired);
- UK photocard driving licences (full or provisional); and
- UK bank accounts with national insurance numbers. In addition, certain security questions will be asked, which should only be answered by the applicant.
It is possible to use the following forms of identification:
- biometric passports (up to 18 months expired);
- non-biometric passports from selected countries (up to 18 months expired);
- UK or EU photocard driving licences (full or provisional),
- UK biometric residence permits (up to 18 months expired), and
- biometric EEA national identity cards. Applicants must also have a UK home address.
The application is initiated and completed via the GOV.UK One Login website, however the information must be submitted in person at a local post office.
ACSP (Authorised Corporate Service Provider)
It is possible to provide a wider range of documents if using the ACSP route, however the exact requirements will depend on what process the ACSP uses to conduct IDV.
The following technologies can be used to validate cryptographic features when using technology capable of doing so: (i) biometric or machine-readable passports or Irish passport cards (up to six months expired); (ii) UK, Isle of Man, Channel Islands or EU photocard driving licenses (full or provisional); (iii) biometric identity cards from EU or EEA; (iv) UK biometric residence permits (up to 18 months expired) or UK biometric residence cards; and (v) UK Frontier Worker permits.
In cases where an ACSP is unable to validate cryptographic features, a person must provide two pieces of evidence from a specified list (one must be photographic, and one must be a government-issued document if the individual does not live in the United Kingdom).
The ACSP will provide a verification statement to Companies House once it has completed IDV. It will contain certain personal information about the individual and the documents used as evidence as well as certain information such as the number of the document or its equivalent, the expiration date, and the country of issue (copies of the documents will not be required).
How does verification work?
As soon as the IDV process is complete, Companies House will provide the individual with an 11-character unique identifier known as a Companies House personal code. Companies House will not disclose personal codes publicly and it should be kept securely. When an individual verifies via an ACSP, they will receive an email containing their personal code. In the event that they verify directly with Companies House, they will be able to see their personal code on the screen (and should take a screenshot of it for their records). Their personal code can be viewed under the “manage account” section of their Companies House account.
The personal code will be used to link an individual’s verified identity with the relevant records at Companies House.
What is the method of storing your personal information?
According to the new IDV legislation, documents and statements delivered to Companies House in connection with IDV requirements will be added to the list of materials unavailable for public inspection at Companies House.
If using an ACSP to undertake IDV, the ACSP is under an obligation to keep records of all the evidence and information used to verify someone’s identity. A copy of the documents checked, evidence of the identity checks performed, and records of any unsuccessful attempts at verification must be kept for seven years following completion of IDV. Companies House guidance confirms that once a person connects their personal code to Companies House records, the public register will display a statement confirming their identity verification. This statement includes the name of the ACSP, the name of the Anti-Money Laundering supervisory body with which the ACSP is registered, and the date the identity checks were completed.
Can reverification be required?
According to Companies House, an IDV will typically only need to be completed once. It is possible for Companies House to require an individual to re-verify their identity if there is reasonable cause to believe that the information or evidence provided was misleading, false, or deceptive. As a result, it will issue a notice requiring reverification within a specified timeframe to the relevant individual. Re-verification will not be required simply because ID documents have expired or been replaced, and it will not be necessary if you change your name, although Companies House has not yet confirmed how the process will work. The Companies House guidance states very clearly that individuals should not verify again unless the company instructs them to do so.
What are the consequences in the event of non-compliance?
Upon the implementation of IDV:
- In the event that the requirements are not met, a criminal offence may be committed and fines or financial penalties may be imposed. The register will also indicate that someone’s identity has not been verified;
- An individual who acts as a director without verifying their identity commits an offence (unless it is exempt1 from verification). An individual may also be disqualified from serving as a director. The appointment of a director will remain valid, and any actions taken by a director whose identity has not been verified will not be contested on the basis of a lack of IDV;
- It is an offense for a PSC (or PSC at the time) who does not complete IDV.
As a practical matter, once IDV becomes a legal requirement, individuals who have not verified their identity will not be able to register at Companies House as directors or members of LLPs once incorporation is completed since IDV must be verified on the application. The new filing requirements will also prohibit them from making filings on behalf of a company once they become effective. As soon as IDV becomes mandatory, any new director joining an existing company will be required to conduct IDV before filing a notice of appointment at Companies House as well as before acting as a director. To ensure directors are able to act as soon as their appointment takes effect, IDV should be completed and confirmed before appointment.
Conclusion
Before IDV becomes mandatory, we recommend to consider making the necessary steps to be UpToDate with the following matters:
- Checking and, if necessary, updating the current filings for directors and PSCs to ensure the information is accurate and consistent;
- Identifying who will be responsible for completing IDV for each company (noting that each individual will only need to complete IDV once); advising relevant individuals of the requirements;
- Assessing any individuals with identity documents that require verification through the face-to-face service or by an ACSP and asking relevant individuals to verify the validity of those documents, including expiration dates;
- Identifying when confirmation statements are due for each company in a group (to ensure that IDV can be completed in sufficient time to avoid late filing penalties);
- Determining by what date each individual PSC of a company must confirm IDV with Companies House;
- Completing IDV on a voluntary basis, if applicable.
In order to avoid potential issues and delays as 18 November approaches and demand increases, companies and LLPs with annual confirmation dates following 18 November 2025 should begin the IDV process during the voluntary window.
Companies House is expected to release further information in the near future, and we intend to update this article accordingly.
UK-Accountant is a registered authorised corporate service provider in the UK and will be happy to assist with all your IDV checks within one day.
Contact us Today to complete your checks at info@uk-accountant.com
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