Companies House Identity Verification: What Agency Directors Need to Know

Companies House is introducing mandatory identity verification for all UK company directors and Persons with Significant Control (PSCs). This is a fundamental change to how Companies House operates, with serious consequences for non-compliance including unlimited fines, criminal penalties, and potential disqualification.

The changes stem from the Economic Crime and Corporate Transparency Act 2023 (ECCTA), designed to tackle fraud and increase transparency in UK corporate structures.

For agency directors, this means new compliance obligations starting 18 November 2025, with tight deadlines that vary depending on your specific circumstances.

What Are the Requirements

The identity verification system applies to specific roles within UK companies, LLPs, and overseas companies with UK establishments.

Who must verify their identity:

Company directors (including those of overseas companies with UK branches) form the largest affected group. This includes executive directors, non-executive directors, and shadow directors where applicable.

Persons with Significant Control require verification if they hold 25% or more of shares or voting rights, or exercise significant influence or control over the company. For most owner-managed agencies, directors are often also PSCs, meaning they need to verify in both capacities.

LLP members must verify their identity under the same framework, ensuring limited liability partnerships face equivalent transparency requirements to limited companies.

Individuals filing documents at Companies House will require verification from Spring 2026. This affects agents, accountants, company secretaries, and anyone submitting filings on behalf of companies.

Critical Dates and Deadlines

The verification rollout follows a phased approach with different deadlines depending on your role and timing.

8 April 2025 marks the opening of voluntary identity verification. Early adoption helps avoid the rush when mandatory verification begins and ensures you're prepared ahead of deadlines.

18 November 2025 represents the key date when mandatory verification starts, but the specific deadline for each person varies:

For new director appointments made on or after this date, verification must be completed before the appointment takes effect. Companies cannot appoint unverified directors after this point.

Existing directors face deadlines linked to their company's next Confirmation Statement date after 18 November 2025. If your confirmation statement is due in December 2025, you must verify before filing. If it's due in June 2026, you have until then.

PSCs who are not also directors must verify by their birth month in 2026. Someone born in March needs to verify by 31 March 2026, whilst someone born in November has until 30 November 2026.

Spring 2026 brings mandatory verification for presenters, or individuals filing documents on behalf of companies. The exact date hasn't been confirmed, but expect this requirement to take effect around March or April 2026.

Summary of Critical Dates

How the Verification Process Works

Companies House offers two main verification routes: direct verification through GOV.UK or indirect verification through an Authorised Corporate Service Provider (ASCP).

Route 1: Direct Verification via GOV.UK One Login

The GOV.UK One Login system provides three verification methods depending on your circumstances and available documents.

The app route offers the fastest verification, typically completed in minutes. You'll need a biometric passport (one with a chip) and a smartphone. The app uses facial recognition technology to match your face against your passport photo, creating a high level of identity assurance.

The web route works for those with UK passports or driving licences who prefer not to use the app. This method requires answering security questions based on your credit file, so it only works if you have a UK credit history. The process takes longer than the app route but doesn't require a smartphone.

Selected Post Offices provide face-to-face verification for individuals without biometric passports or those who prefer in-person verification. You'll need to book an appointment, bring acceptable identification documents, and pay a fee. This option particularly helps older directors or those uncomfortable with digital verification.

Route 2: Via an Authorised Corporate Service Provider (ASCP)

Authorised Corporate Service Providers offer verification services as an alternative to the GOV.UK route. This option particularly benefits:

• Non-UK residents without UK identification documents
• Individuals without UK credit history for web verification
• Directors who prefer professional assistance through the process
• Those needing verification for multiple individuals simultaneously

ASCPs can accept a wider range of identity documents than Companies House's direct system, including overseas passports and identity cards. They guide you through the process and handle the technical aspects of verification.

Each ASCP sets their own fees and service levels. Some accountancy firms and corporate service providers have obtained ASCP status, allowing them to verify their clients' identities as part of their service offering.

Acceptable Identity Documents

The verification system accepts specific documents with varying levels of assurance.

Biometric passports (UK or international) provide the highest level of identity assurance and enable the fastest verification through the GOV.UK app. Most modern passports issued since 2006 contain biometric chips.

UK driving licences (photocard type) work for web-based verification but cannot be used with the app route. Older paper licences are not acceptable.

Other acceptable documents depend on your verification route. ASCPs may accept overseas identity cards, residence permits, or other documents that Companies House's direct system doesn't support.

You'll need documents that are current and valid—expired documents won't be accepted regardless of the verification route chosen.

Your Personal Verification Code

Once verified, you receive an 11-digit personal verification code. This code proves your identity for all future dealings with Companies House.

Safeguarding your code is essential, thus treat it like a password. You'll need this code when:

• Being appointed as a director of any company
• Registering as a PSC
• Filing documents at Companies House (from Spring 2026)
• Making changes to your directorship details

The code remains valid indefinitely and doesn't need renewal, but if you lose it, you'll need to go through the verification process again to obtain a replacement.

Never share your verification code with anyone except when making official filings at Companies House. Legitimate service providers may ask for your code to complete filings on your behalf, but be certain you're dealing with trusted parties.

Planning Your Verification Timeline

Strategic timing of verification can reduce stress and avoid last-minute complications.

Verify early if you're:

• Appointing new directors in the next 12 months
• Planning business restructuring involving directorship changes
• Expecting to file documents at Companies House regularly
• Managing multiple companies with different confirmation statement dates

Check your confirmation statement date to understand your specific deadline. You can find this on Companies House records or through your accountant. Companies with confirmation statements due shortly after 18 November 2025 should prioritise verification.

PSCs should note their birth month as this determines their verification deadline in 2026. Verification typically takes only a few days through the app route but can take weeks via Post Office or ASCP routes, so plan accordingly.

Consequences of Non-Compliance

Companies House has significant enforcement powers for verification failures, and they've indicated these will be used.

Blocked filings represent the immediate consequence. Companies cannot file confirmation statements, annual accounts, or other documents if directors or PSCs remain unverified past their deadlines. This creates cascading compliance problems as other deadlines pass.

Financial penalties can reach unlimited amounts under the regulations. Whilst initial fines may be modest, persistent non-compliance attracts increasingly severe penalties.

Criminal sanctions apply for deliberate failures to verify identity. The legislation treats verification as a fundamental compliance requirement, not an optional administrative task.

Director disqualification becomes possible for serious or repeated failures. Disqualified individuals cannot act as directors or directly manage companies for specified periods, effectively ending their ability to run businesses.

Practical business impacts extend beyond formal penalties. Banks increasingly require verified director status for business accounts, lenders check verification for loan applications, and business partners may question dealings with unverified directors.

Summary of Consequences

Managing Multiple Directorships

Agency owners often hold directorships across multiple companies—operating companies, holding companies, property companies, and other structures. The verification requirements apply to each directorship, but you only need to verify your identity once.

Your 11-digit verification code works across all your directorships and all companies you're involved with. Once verified, you can use the same code for:

• All existing directorships when their deadlines arrive
• New appointments in other companies
• PSC registrations across multiple entities

This means early verification provides immediate benefit across your entire portfolio of directorships rather than requiring separate processes for each company.

Special Considerations for Agency Structures

Service-based agencies often have structural quirks that affect verification requirements and timing.

1. Parent-subsidiary structures mean checking verification requirements for directors and PSCs at each level. Holding company directors need verification even if they're not involved in day-to-day operations.
2. Management companies established for office space or equipment may have directors who rarely consider their formal roles. These still require verification within applicable deadlines.
3. Dormant companies maintained for name protection or future use still require director verification. Dormancy doesn't exempt directors from verification obligations.
4. Joint venture entities where you hold minority directorships require verification even if you're not a PSC. Your role as director triggers the requirement regardless of shareholding.

Looking Ahead: Future Verification Requirements

The verification system represents the first phase of broader Companies House reforms under ECCTA. Additional changes coming in subsequent phases include:

Enhanced company information requirements for greater transparency around business activities and ownership structures. Stricter filing requirements with potential for Companies House to query or reject filings that appear inconsistent or suspicious. Expanded powers for Companies House to remove incorrect information and investigate potential fraud.

Identity verification creates the foundation for these enhanced powers by ensuring Companies House knows who actually controls and manages UK companies. Staying ahead of verification requirements positions you well for these additional changes.

Get Professional Support

Whilst verification itself is straightforward for most directors, the broader compliance implications may warrant professional guidance, particularly for complex agency structures or international operations.

Professional advisers can help identify all individuals requiring verification across your structure, determine optimal verification routes for your circumstances, coordinate verification across multiple directors and PSCs, integrate verification into broader compliance planning, and ensure verification timing aligns with other corporate actions.

The cost of professional support typically proves minimal compared to risks of non-compliance or complications from rushed last-minute verification.

Need help managing Companies House verification for your agency? 

We can help you review your director and PSC positions, coordinate verification timing across your entities, and ensure full compliance with these new requirements. 

Book a consultation today to discuss your specific circumstances and create a verification plan that works for your business.

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