The Economic Crime and Corporate Transparency Act 2023 (ECCTA) introduces identity verification (IDV) requirements for certain individuals with control of UK companies. See our previous article for further detail of these changes and how to prepare. Companies House has announced that the rollout of mandatory IDV will begin on 18 November 2025.
From 18 November 2025, IDV will be a compulsory part of incorporation and new appointments for new directors, members of LLPs and persons with significant control (PSCs). IDV will be phased in over a 12-month period. The due date for IDV for individuals will be determined by their specific role.
Companies House estimates that 6 to 7 million individuals will need to verify their identity by mid-November 2026. Individuals have been able to voluntarily verify since 8 April 2025, and more than 300,000 have already done so.
IDV requirements for limited partnerships, corporate directors of companies, corporate members of LLPs, and officers of corporate PSCs will commence at a later date.
ID verification requirements may be relevant on M&A transactions completing after 18 November where individuals are to be newly appointed directors of the acquired company or where individuals become new PSCs. However, identity verification for officers of corporate PSCs where the buyer is a company won't be required until the relevant regulations come into force.
What’s changing?
From 18 November 2025:
- new directors will need to have their identity verified before being appointed to an existing company or on incorporation of a new company
- existing directors will need to confirm their identity has been verified when the next annual confirmation statement for the company is filed (meaning that there is a 12-month transition period)
- PSCs will need to have their identity verified within a specified timeframe. For existing PSCs this will be in line with an appointed day within 12 months of 18 November
The announcement from Companies House didn't set out detail of the provisions applicable to LLP members, but we expect that these will mirror the requirements of company directors.
Non-compliance will be an offence, potentially resulting in financial penalties, plus you’ll be shown as “Unverified” on the Companies House register. The onus is not just on individuals, as the company itself and all other directors may also be committing an offence where the company has an unverified person acting as a director.
PSCs
PSCs have a 14-day period to submit:
- a statement confirming they have verified their identity
- their Companies House personal IDV code
The dates of the 14-day period are determined as follows:
Date of being registered as a PSC |
When does the 14-day period start? |
| Registered as a PSC after 18 November 2025 |
14-day period starts from the date they register with Companies House |
|
Already registered as a PSC on 18 November 2025 and a director of the same company |
14-day period starts from the date of the company’s next confirmation statement |
|
Already registered as a PSC on 18 November 2025 and not a director of the company |
14-day period starts from the first day of their month of birth, as it is shown on the Companies House register (eg if the PSC’s date of birth is 2 April 1990 and shown on the register as April 1990, the 14-day period will start on 1 April 2026) |
What are the benefits of identity verification now?
While identity verification is currently voluntary, we don't see any reason to delay getting verified.
It's free to apply directly via Companies House for ID verification using the GOV.UK One Login and for the majority of users the process is quick and simple (the average completion time for the ID Check App is 2.4 minutes!).
In our experience, some users of the service have been met with technical glitches and have needed a few attempts to get verified. We'd therefore recommend starting the process early to allow time to resolve any technical issues – particularly as we expect the service will get busier in the run up to the commencement date of mandatory identity verification.
Next steps for you
- Determine whether you need your identity verified.
- If you're a company director, consider which other individuals will need IDV for their involvement in the company (including PSCs).
- Determine the date by which you need to have completed IDV. From 18 November, directors and PSCs will be able to check the Companies House register to see IDV due dates for all their roles.
- 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.
- You'll receive a Companies House personal code when your identity has been verified. This unique identifier is personal to you. Keep this safe, you’ll need to provide the code to Companies House as part of certain filings.
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 - When you need to verify your identity for Companies House - GOV.UK - which sets out information on the identity verification process.
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