Major reforms to UK company law: Rollout of mandatory identity verification starts today

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) introduces identity verification (IDV) requirements for certain individuals with control of UK companies. The rollout of mandatory IDV starts on 18 November 2025.

Background

ECCTA introduces substantial reforms to the requirements and procedures for forming and managing companies in the UK. As part of efforts to tackle corruption, money laundering and fraud, ECCTA has introduced mandatory identity verification (IDV) for specific individuals linked to UK companies and LLPs, including directors, LLP members and persons with significant control (PSCs).

IDV at Companies House is not to be confused with the proposed new digital ID scheme to be rolled out across the UK to combat illegal working. This IDV framework is designed to improve corporate transparency and ensure the reliability of information held on the Companies House register.

Existing directors, LLP members and PSCs have been able to voluntarily verify their identity with Companies House since 8 April 2025. According to Companies House, out of the estimated 7 million existing directors and PSCs, more than a million individuals completed IDV under the voluntary scheme. The remainder will be required to do so during the 12-month transition period starting on 18 November 2025.

The Companies House ”Find and update company information” service has been updated to indicate:

• Whether individuals have had their identity verified at Companies House.
• If an individual’s Companies House personal code has not been filed, the date that IDV is due.

Remember that Companies House does not automatically match your IDV to your roles with different companies or LLPs. Completion of IDV is the first step, but a filing will also need to be made at Companies House.

Filing your Companies House personal code

You'll receive a Companies House personal code when your identity has been verified. This 11-character code is personal to you.

Your code should appear on screen once your IDV is complete, and we recommend taking a note of this for your records. If you verified your identity directly with Companies House, your code should be available on the “Manage account” section of your Companies House account. However, we are aware that some people have struggled to get access to the website due to technical issues, so having your own record may be helpful.

The date by which IDV will need to be completed (and the code filed at Companies House) depends on the company you are connected with and your role.

You can now check the Companies House website to see the due date for IDV for your role(s). The due dates are determined by specific roles and company so you may have multiple filing dates. For example, if you are a director of both Company A and Company B then there may be separate due dates for each company, or if you are both a director and PSC of Company C then there may be different due dates for the separate roles.

Managing your Companies House personal code

Keep your Companies House personal code safe. The code is unique to you and should be treated as personal information (like a passport number) rather than public information (like a company number).

A key objective of the IDV system is to enhance security around company information and filings. 

You may need to share the code with other people, such as someone filing at Companies House on your behalf. However, your code should be kept securely and not made widely available.

Increased importance of filing obligations

Under ECCTA, directors may face disqualification if they have committed three or more “defaults” within the preceding five years. These defaults include financial penalties and relate to persistent non-compliance with key provisions of UK company legislation, including failure to meet statutory filing obligations and non-compliance with IDV requirements for directors and PSCs.

It is therefore important for directors to understand their filing obligations and the status of compliance with IDV requirements for all relevant individuals connected with their company, rather than just themselves personally.  

Future changes

ECCTA reforms which will require:

• Companies to provide statements that their directors and PSCs are not disqualified from acting as a director.
• Corporate directors and registrable relevant legal entities of companies to provide a service address.
• Registrable relevant legal entities to have a relevant officer whose identity is verified are not yet in force. 

You should also be aware that provisions which require IDV for individuals who make filings at Companies House on behalf of companies are currently expected to come into force in spring 2026.

Changes to company registers

Further ECCTA reforms in force from 18 November 2025 include the removal of the requirements under the Companies Act 2006 for companies to maintain their own:

• Register of PSCs
• Register of directors
• Register of directors’ residential addresses
• Register of secretaries

The obligation to maintain these registers has been replaced with a requirement to file specified information at Companies House. 
While the Companies House record will become the verified source of information in respect of these registers, companies should retain their registers containing the historic information. Companies may also decide, as a matter of good governance, to continue to maintain these registers in addition to the information filed at Companies House.

In recent years, private companies have had the option to elect to hold their register of members centrally at Companies House rather than in local registers. Companies House had previously indicated that companies would no longer be able to use the central register from 18 November. However, this option has not yet been withdrawn.

Next steps for you

1. Determine whether you need your identity verified.
2. If you're a company director, consider which other individuals will need IDV for their involvement in the company (including PSCs).
3. Check the Companies House website to see the date by which you need to have completed IDV for each role. Remember that there may be different dates for filing your Companies House personal code if you are both a director and a PSC. 
4. If your identity needs to be verified; set up a GOV.UK One Login and apply to Companies House for IDV or appoint an ACSP to verify your identity.
5. Once your identity has been verified, keep your Companies House personal code safe and accessible. You’ll need to provide the code to Companies House as part of certain filings.
6. If you’re a company director, you should review your company’s registers of directors, directors’ residential addresses, secretaries and PSCs and check that the information required to be set out in them is readily available and up to date as of 18 November 2025 if you choose not to continue to maintain them.

What do I need to do next?

If you have any questions, please get in touch with your usual contact at Mills & Reeve, or alternatively refer to the government website, which sets out information on the identity verification process.

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