Legal Briefing: Company Law Update - Identity Verification for Directors and Persons with Significant Control of UK companies

Identity verification is currently voluntary. Companies House has now confirmed that this requirement will become mandatory for existing individual directors and PSCs of companies from 18 November 2025, with a 12-month transition period.  Companies should begin preparing now to ensure compliance.

Identity verification will also become mandatory for individual members of limited liability partnerships (LLPs).  We will issue a separate update when Companies House issues further guidance on this.

This briefing note focuses on the requirements for UK companies. 

Who Must Verify Their Identity?

Directors

From 18 November 2025, all individual directors of UK companies must verify their identity:

• Existing directors: Must verify their identity before filing of their company's next confirmation statement after 18 November 2025
• New directors: Must verify their identity before being appointed (or in the case of new incorporations, before submitting the application for incorporation) Persons with Significant Control (PSCs)
  Verification requirements also apply to PSCs of a company:

• Existing PSCs: Must verify their identity within 14 days of a designated date, which varies depending on their role:
  • If the PSC is also a director, the 14-day period begins on the company’s next confirmation statement date after 18 November 2025.
  • If not a director, the 14-day period begins on the first day of their birth month as recorded at Companies House. For example, if the register shows a birth date of March 1990, the 14-day window starts on 1 March 2026.
• New PSCs: Must verify their identity within 14 days of registration with Companies House.
• PSCs will be required to provide their unique codes with the relevant 14-day period using a separate service available from 18 November 2025.

From 18 November 2025, directors and PSCs will be able to check the Companies House register to see identity verification due dates for all their roles.

Why is this important?

ECCTA introduces new sections of the Companies Act that will: (i) prohibit any individual acting as a director unless their identity has been verified by the requisite deadline (unless one of the limited exemptions from verification applies); and (ii) require the company to ensure that an individual does not act as a director unless their identity is verified.  Breach of these new sections will be a criminal offence.

How to Verify Identity

Companies House has stated that they intend that identity verification will be a one-time process (unless the Registrar considers the information provided by an individual is false, misleading or materially deceptive). 

There are two approved methods:

1. Companies House Service (GOV.UK One Login)

• Free to use and accessible via app, web, or in-person at selected Post Offices.
• The system selects the most suitable method based on the applicant’s identity documents.
• A verified individual will need to provide Companies House with their personal code and a verification statement for each role they hold as a director and/or a PSC and for each company if they hold appointments for multiple companies.

2. Authorised Corporate Service Provider (ACSP)

• ACSPs are third-party providers authorised to submit information to Companies House on behalf of their clients
• Certain ACSPs are providing identify verification services
• The process varies depending on the provider’s systems and the applicant’s documents.
• Once verification is complete, the ACSP submits a verification statement to Companies House, and the individual receives their unique identifier.
• Fieldfisher, like most City law firms, has registered as an ACSP so that it can continue to make Companies House filings on behalf of clients but not to provide identification verification services.
• Specialist platforms that are registered as ACSPs and that do provide identification verification include Elemental and Law Debenture
• Fieldfisher can introduce or liaise on your behalf with a specialist provider for these purposes, should you require any support with this.

Practical steps and considerations

These reforms will require companies to take some steps now to ensure they avoid breaching the new sections. Next steps include:

• Informing all directors and PSCs about the new identity verification requirements. 
• Determining whether each relevant individual can use the Companies House identity verification system.  Where necessary, consider using an ACSP to complete the verification process.
• Beginning the verification process as soon as possible, particularly for overseas individuals, as verification may take longer. 
• Tracking completion of the verification process to ensure compliance within the applicable timescales.
• Checking that the details of all directors and PSCs on the Companies House register are accurate and up to date, especially in relation to dates of birth.
• Keeping a secure record of each individual’s unique identifier code, in line with applicable privacy and record keeping policies.
• Contacting the Fieldfisher company secretarial team or your usual Fieldfisher contact with any queries, including about using an ACSP for identity verification. 

This briefing is up to date as of 8 August 2025. 

Stay informed with updates on ECCTA from Fieldfisher        

See these other ECCTA updates from Fieldfisher:

Identity verification under the Economic Crime and Corporate Transparency Act 2023 — what it means for your company | Fieldfisher

Guide to the Economic Crime and Corporate Transparency Act 2023 | Fieldfisher

Look out for upcoming briefings on the identity verification requirements for LLPs, changes to accounts filing requirements and maintaining statutory registers.