Authors
Last month, Companies House released new guidance on the upcoming Identity Verification (IDV) requirements, introduced by the Economic Crime and Corporate Transparency Act 2023 (ECCTA). The new legal requirement will see individuals including directors, people with significant control (PSCs), Authorised Corporate Service Providers (ACSPs) and those filing information with Companies House, for example, company secretaries, having to verify their identity. This is designed as part of the Government’s crackdown on economic crime, to ensure that there is improved transparency, trust and accuracy of information held on the Companies House register and to also limit the risk of fraud.
The article we published last autumn dealt with the relevant provisions and regulations applicable to the introduction of IDV, ACSP and Unique Identifiers (UIN). This article provides an update to this and sets out a step-by-step guidance on everything you need to know about verifying your identity for Companies House, who needs to undertake the IDV, the different routes available for verification, the timeframe for completing the IDV process and the consequences for failing to comply.
Who needs to verify their identity?
As outlined above and in the Government’s Transition Plan for Companies House, new directors and PSCs, existing directors and PSCs, any members of a limited liability partnership (LLP), general partners, managing officers, ACSPs and anyone acting on behalf of a company will need to verify their identity.
When you need to verify
On 18 March 2025, Companies House began the registration process for the application of UK firms or organisations regulated by AML laws to apply for authorisation as agents or ACSPs. Alongside this, Companies House also published relevant guidance on how to apply.
From 8 April 2025, ACSPs can verify their clients’ identities and must follow the guidance published by Companies House regarding the legal standards that ACSPs must meet when conducting IDV for their clients. From this date, directors, PSCs, members of LLPs etc. may choose to verify their identity on a voluntary basis.
The date for the mandatory IDV has yet to be confirmed, but the Transition Plan indicated that from autumn 2025, IDV will become compulsory part of incorporations and new appointments for directors, PSCs, members of LLP etc. The 12-month transition phase will also begin from this period which will require all existing directors, PSCs, members of LLPs etc. to verify their identity as part of the annual confirmation statement filing.
Ways to verify your identity
There are two ways in which you will be able to verify your identity – The first route is via the GOV.UK One Login (which can be done online or in person at a Post Office) and the second route is via an ACSP.
1. Free Online via GOV.UK One Login
You can verify your identity online for free using GOV.UK One Login, if you have one of the following types of photo IDs:
- biometric passport from any country
- UK photo driving licence (full or provisional)
- UK biometric residence permit (BRP)
- UK biometric residence card (BRC)
- UK Frontier Worker permit (FWP)
If you do not have one of the above listed IDs but live in the UK, you may be able to verify using bank or building society details.
You will be asked a few simple questions from GOV.UK One Login to find the best way for you to verify your identity online and you will either be directed to verify through the GOV.UK mobile phone app or via a web browser.
In person at a Post Office
If you are unable to verify your identity online and you live in the UK, you may have the option to verify in person at a Post Office. To determine if this method is available to you, please use the ’Verify your identity for Companies House’ service – this service will become available from 8 April 2025. This process utilises GOV.UK One Login for identity verification and is free of charge. For further information on how to use GOV.UK One Login, please see, here: Using your GOV.UK One Login: Proving your identity with GOV.UK One Login – GOV.UK
2. Using an Authorised Corporate Service Provider (ACSP)
An ACSP (also known as Companies House authorised agents, such as solicitors or accountants), can verify your identity. They must be registered with Companies House and a UK Anti-Money Laundering (AML) supervisory body. You will need to provide them with approved identity documents, and they may charge a fee for their services.
What happens when you verify?
Once you have successfully verified your identity, you will receive a Unique Identifier (UIN) also known as a Companies House personal code. This code is personal to you and not your company. For more details about the UIN, please refer to our previous article here.
From autumn 2025:
- You will need to have your personal code to file your confirmation statement, if you are appointed as a director or if you become a PSC.
- If you are currently a director or a PSC, you’ll need to use your personal code to connect your verified identity to Companies House’s records. This legal requirement will mean that Companies House can see that the correct identity is linked to any roles that individual holds.
- Current directors must provide their personal code in the next confirmation statement and new directors must provide it when being appointed or incorporating a new company. PSCs will also need to provide their personal code and ACSPs must provide the code to register. Therefore, it is important to keep your personal code safe, as you would with other unique codes such as your Unique Taxpayer Reference (UTR) for HMRC.
What happens if you do not verify?
Failing to verify your identity once it becomes a legal requirement will mean that you will not be able to make any filings with Companies House, set up a new company or register as an ACSP. For directors and PSCs, this could result in committing an offence, and you may have to pay a financial penalty or fine. Directors who continue to act without their ID verified could face disqualification and every director of the company may also be punished by default.
How to prepare
In summary, any individual that wishes to set up, own, run, or control a company in the UK must have their identity verified by law. As of now, organisations should ensure that their current directors and PSCs are familiarised with the new IDV regime and have up-to-date and accurate ID documents ready for when they can voluntarily verify their identity from 8th April 2025. Companies House have asserted the necessity for individuals to have their ID verified in advance of the company’s next confirmation statement, as this will need to be confirmed when making the filing. Consequently, preparation will be key when it comes to completing IDV in a timely manner, especially ahead of filing an appointment. It is also important for those who have successfully verified their ID, to keep possession of their allocated personal code or, if appropriate, share it with people they trust to file with Companies House on their behalf. The personal code will be required when you file your confirmation statement or if you are appointed as a director or PSC. For further information regarding the IDV changes, please see here: Verifying your identity for Companies House – GOV.UK
How can Michelmores assist?
- We want to help our clients navigate the changes introduced by the implementation of the ECCTA. We will continue to monitor the developments and publish further updates on our ECCTA Hub as and when the Government announces new measures.
- Michelmores has a dedicated Corporate Services team led by experts in company law and corporate governance. The team will be happy to speak with you if you want to know more about the forthcoming Companies House reforms or how ECCTA will affect your company or organisation.
Sources
Applying to register as a Companies House authorised agent – GOV.UK
How to meet Companies House identity verification standard – GOV.UK
Verifying your identity for Companies House – GOV.UK
Identity verification – Changes to UK company law
Using your GOV.UK One Login: Proving your identity with GOV.UK One Login – GOV.UK
Authors