Identity verification
The Economic Crime and Corporate Transparency Act 2023 introduces an identity verification requirement for various categories of people (including directors, persons with significant control ("PSCs") and those filing documents at Companies House).
In our article in March (see here) we explained the methods an individual can use to verify their identity.
A person who completes the identity verification process will receive a personal code. That code (together with a statement confirming that the person's identity has been verified) will need to be provided to Companies House in a number of situations. A person only needs one code (as opposed to a code for each position they hold/company they are involved with).
Since 8 April it has been possible for individuals to voluntarily verify their identities. However, Companies House have now announced (see here) that with effect from 18 November 2025 identity verification will start to become mandatory. The exact impact of this depends on the situation.
- Companies formed on or after 18 November 2025
Anyone registering a new company will be required to provide Companies House with the personal code for each proposed director.
- A person who is appointed as a director on or after 18 November 2025
They will need to provide their personal code as part of the appointment process.
- A person who becomes a PSC on or after 18 November 2025
They will need to provide their personal code to Companies House within 14 days of being added to the Companies House register of PSCs.
As regards existing directors and PSCs, a 12 month transition phase will begin on 18 November 2025. The timings differ depending on a person's role.
- A person who is an existing director
They will need to verify their identity before the next confirmation statement for the relevant company is filed and they will need to provide their personal code as part of the confirmation statement filing. Those with multiple directorships will be required to do this for each company of which they are a director (although they will use the same code for each company).
- PSC who is also a director of the same company
They will need to provide their personal code separately for each of those roles.
As a director, as noted above, the code will need to provided as part of the company's next confirmation statement.
As a PSC, the code will need to be provided via a separate online process within 14 days of the relevant company's confirmation statement date.
- PSC who is not a director of the same company
They must provide their personal code within the first 14 days of their birth month. For example, if their birthday is in January, their 14 day period will begin on 1 January 2026.
Companies House have said they will contact companies to inform them of the requirements and that 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.
Mandatory identity verification will also commence for members of limited liability partnerships on 18 November 2025 (see here). Although not explicitly covered in the announcement (see above), the requirements and timings for individual LLP members are expected to be the same as for individual directors.
Identity verification requirements for limited partnerships, corporate directors of companies, corporate members of limited liability partnerships, officers of corporate PSCs and those people filing information on behalf of companies will commence in 2026.
Statutory registers
From 18 November 2025 the only statutory register a company will need to keep itself will be the register of members (see here). All other registers (including the register of directors, register of directors' residential addresses, register of secretaries and the PSC register) will be kept centrally by Companies House. Companies will be under an obligation to register the relevant information with Companies House and keep it up to date.
In addition, from 18 November 2025, the current option for companies to keep their register of members centrally at Companies House will be abolished and all companies will be required to keep and maintain their own register of members.
If you require any further information, or specific advice, please contact our Corporate Secretarial Services team.
