Mandatory Identity Verification for UK Company Directors and PSCs: What Businesses Need to Know

The Economic Crime and Corporate Transparency Act 2023 introduced ID verification requirements for company directors and people with significant control (“PSCs”).

The aim is to enhance the accuracy of the companies register, prevent misuse, and foster a more secure business environment.

So what do businesses need to know?

PHASED ROLL OUT

The Act left it open for the new requirements to be phased in gradually. Companies House has announced the phased introduction of mandatory ID verification, starting on 18 November 2025.

However, the ability to start the process early on a voluntary basis came into effect on 8 April 2025.

Our advice: don’t wait for the deadline; start early. Taking care of it early will make things easier down the line.

KEY DATES AND REQUIREMENTS

Existing Directors and PSCs

• Current directors must confirm their ID verification status when filing their next annual confirmation statement during a 12-month transition period.

• Existing PSCs must verify their identity within a specified timeframe based on their role and registration details:
  • If the PSC is also a director: Verification must be completed within 14 days of the company’s next confirmation statement date.
  • If the PSC is not a director: Verification must be completed within 14 days of the first day of their birth month as recorded at Companies House.
    Example: If a PSC’s birth month is December, the 14-day window begins on 1 December 2025.

New Directors and PSCs

• From 18 November 2025, all new directors must verify their identity before company incorporation or appointment.

• New PSCs must complete verification within 14 days of registration.

VERIFICATION PROCESS

The ID verification process can be completed:

• Online via GOV.UK One Login; or

• Through an Authorised Corporate Service Provider (ACSP) – being those individuals or organisations that undertake AML supervised activity such as accountants, solicitors or company formation agents.

The process is designed to be quick, secure, and free of charge, and most individuals will only need to verify once. Once your verification is successfully completed, Companies House will issue you with a unique identifier known as a personal code. This code is specific to you as an individual and is not linked to your company or any organisation you work for. If you are a director overseeing multiple companies, you’ll need to submit the same code along with a verification statement for each of those companies.

We have observed that some users have encountered difficulties using the Companies House platform on personal computers. Therefore, we recommend using an NFC-enabled mobile phone for a smoother experience.

Should you run into any issues verifying your identity online, you can always opt for in-person verification using One Login at a designated Post Office or we recommend you opt by completing the process through an Authorised Corporate Service Provider (ACSP).

If you don’t have a biometric passport, you may need an ACSP to verify your identity. This is especially important for overseas directors without biometric passports or when the name at Companies House doesn’t match the ID. Identifying these cases should be a top priority.

Finally, it is important you ensure you have an email address that is unique and not shared with any other director, PSC, or the company’s registered email.

ENFORCEMENT AND PENALTIES

It will be an offence to act as a director without having completed identity verification once the new requirements take effect on 18 November 2025.

Companies House has indicated it will adopt a proportionate approach to enforcement, focusing on supporting businesses to meet their obligations during the transition period.

PRACTICAL STEPS

• Prepare Early: Begin ID verification as soon as possible, don’t wait for the mandatory deadlines to apply in November 2025. Early action will reduce the risk of delays and allow time for resolving any issues.

• Monitor Deadlines: Directors and PSCs should check their verification of due dates as outlined above, i.e., to check when the company’s next confirmation statement is due after 18 November 2025.

• Stay Informed: Companies House will communicate updates to registered email addresses (mandatory since March 2024). We recommend you ensure the company’s email address is current.

• Records: Retain everyone’s unique identifier code in line with privacy and record-keeping obligations.

FINAL POINT

There will also be an additional change which will apply from 18 November 2025. Companies will no longer be required to maintain their own statutory registers of directors, directors’ residential addresses, secretaries, or PSCs. All relevant information will instead be filed with Companies House.

If you need assistance with updating company records, please contact Kyri Papantoniou, Corporate Partner at gunnercooke.

ABOUT KYRI

Kyri is a specialist corporate finance and commercial lawyer focused on M&A, disposals, venture capital, private equity, and corporate restructuring. He supports entrepreneurs and fast-growth businesses from start-up to exit, advising on fundraising rounds (venture capital, growth capital, Series A and beyond) and strategies to maximise business value on sale. Kyri also assists international companies investing in the UK through acquisitions, leveraging his network to connect clients with the right talent.