Article / 2 Apr 2025

Identity verification: who, when and how?

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Gateley Legal

Of the many legal reforms implemented by the Economic Crime and Corporate Transparency Act 2023 (ECCTA), the introduction of identity verification procedures for specified individuals (including directors, Persons with Significant Control (PSCs) and filing agents), is potentially the most significant.

Companies House has recently published new guidance on the verification process and has confirmed that individuals will be able to voluntarily verify their identity directly with Companies House from 8 April 2025 (with compulsory verification being introduced at a later date).

  • Who needs to verify their identity?

    Each of the following individuals will be required to verify their identity within a specific timeframe:

    • Directors – all existing and newly appointed individual company directors (including shadow directors);
    • PSCs – all existing and newly appointed PSCs (and if a registrable PSC is a legal entity, that entity must nominate an individual managing officer whose identity must be verified);
    • LLP members – all existing and newly appointed members of LLPs (and if a member is a corporate entity, its individual directors will be required to verify);
    • General partners of limited partnerships – corporate general partners must appoint a registered officer who is an individual and whose identity must be verified; and
    • Individual filing agents – all individuals delivering documents to Companies House, whether on their own or another’s behalf, will be required to verify their identity (with limited exceptions).

    Identity verification should only need to be carried out once, with verified individuals being allocated a unique identification number (UIN). Companies House will be able to use the UIN to link the records of verified individuals holding multiple roles in different organisations.

  • When to verify?

    All individuals may voluntarily verify their identity directly with Companies House from 8 April 2025.

    The dates for compulsory verification have yet to be finalised and will vary depending on the individual’s role. However, the Government’s outline transition plan indicates the following timeline:

    By Autumn 2025:

    • Identity verification will be compulsory for new incorporations (the statement of proposed officers must confirm that each individual has been verified), and for the appointment of new directors and new PSCs post-incorporation.
    • A 12-month transitional period for existing directors and PSCs to verify their identity will begin (with verification required by submission of the company’s next annual confirmation statement during that period).
    • Although not expressly stated in the transition plan, it is assumed that verification by new members of LLPs will also be compulsory from Autumn 2025, with a 12-month transitional period for existing members beginning at that time.

    By Spring 2026:

    • Anyone delivering information to Companies House on behalf of any registered entity, will have to be verified (or be registered as an Authorised Corporate Service Provider (ACSP) – see below.)

    By the end of 2026:

    • Corporate general partners of new limited partnerships must appoint a registered officer whose identity has been verified. Existing limited partnerships will have a transitional period of six months in which to provide the registered officer details to Companies House.

  • How will the verification process work?

    From 8 April 2025, individuals will be able to verify directly with Companies House, either online or in person (at a post office). Both routes require a Gov.UK One Login and are free of charge.

    Individuals should be able to verify online with Companies House if they have one of the following types of photo ID:

    • biometric passport from any country;
    • UK photo driving licence (full or provisional);
    • UK biometric residence permit;
    • UK biometric residence card; or
    • UK Frontier Worker permit.

    Once signed in, GOV.UK One Login will guide the user to verify their identity using either the GOV.UK ID Check app (which will require access to a phone with a working camera to complete a facial scan), or by answering security questions via a web browser. As well as providing identity documentation, individuals will need to provide a valid email address and a current residential address.

    If an individual is not able to verify online and lives in the UK, it may be possible to verify in person at a post office that offers ‘in-branch verification’. Specified photo ID will still be required and this will be scanned by the post office and a photo of the individual taken.

    Although it is envisaged that most individuals will be able to verify directly with Companies House via the GOV.UK One Login service, there will be some restrictions, particularly in the case of non-UK or non-EU nationals who do not have biometric identification. If individuals are unable to satisfy the documentation requirements for direct verification, they will need to engage an ACSP to verify their identity.

    ACSPs are individuals or organisations that are authorised by Companies House and are supervised within the UK by one of the relevant anti-money laundering supervisory bodies. The application process to register as an ACSP only opened on 18 March 2025, and so it is not yet clear how many organisations will have achieved ACSP status by 8 April (when voluntary verification begins). The verification checks undertaken by ACSPs will achieve the same level of assurance as those undertaken by Companies House. ACSPs will also be authorised to file information at Companies House for their clients.

  • What are the consequences of failing to verify?

    Anyone who fails to comply with compulsory identity verification requirements will be committing an offence, as will any company with an unverified director.

    In addition to fines, failure to verify may result in:

    • disqualification for unverified directors;
    • rejection of incorporations where directors (or their equivalents) have not been verified; and
    • individuals being prohibited from submitting filings at Companies House.

Practical steps

Although mandatory verification is not due to be rolled out until autumn of this year, existing directors, LLP members and PSCs may want to take the opportunity to verify their identity voluntarily from 8 April. Relevant individuals will need to ensure that they have the appropriate identification documents to register directly with Companies House. If they are unable to satisfy the Companies House requirements, an ACSP will have to be engaged.

Businesses should also consider who within their organisation currently files information at Companies House and be alert to the need for them to have their identity verified by spring 2026. Alternatively, companies may want to consider appointing an ACSP to carry out this function in due course.

For more information

For more information on the legal reforms introduced by ECCTA, visit our ECCTA Hub.