TRW & Co · Company law and governance
Companies House Identity Verification: What Directors and PSCs Must Do
Companies House identity verification has been a legal requirement since 18 November 2025. Directors, LLP members and individual PSCs must verify once, through GOV.UK One Login or an authorised agent, and supply an 11-character personal code by their deadline. Existing directors do so with the next confirmation statement; PSCs have a fixed 14-day window. Non-compliance is a criminal offence.
Key pointA company cannot file its confirmation statement unless every director is verified, and a director who is also a PSC must supply the same personal code twice: once in the confirmation statement and again through the PSC service within a separate 14-day window.
At a glance
In force since November 2025
Identity verification became a legal requirement on 18 November 2025, starting a 12-month transition for existing directors and PSCs to verify by their due dates.
Existing directors' deadline
Directors in post before 18 November 2025 must provide their personal code with the company's next confirmation statement filed from that date.
Fixed PSC windows
PSCs who are not directors supply their code in the first 14 days of their birth month; new PSCs on registration or within 14 days.
Two routes only
Verify free through GOV.UK One Login, using the app, online questions or a Post Office, or through a Companies House authorised corporate service provider.
Offences and enforcement
Acting as an unverified director is an offence under section 167M; Companies House can prosecute, impose financial penalties or refer cases to the Insolvency Service.
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The short answer: who needs Companies House identity verification
Companies House identity verification is now a legal requirement for every company director, every LLP member and every individual person with significant control (PSC). As of October 2026, the 12-month transition that began on 18 November 2025 is almost over. If you were already a director, you must have verified and supplied your personal code with your company's first confirmation statement filed in that period.
New directors must be verified before they can be appointed or incorporate a company. Each PSC has a fixed 14-day window to supply their code. Failing to comply is a criminal offence for the individual and, for directors, for the company and its officers too.
Verification is a one-off step for each person. You verify once, receive an 11-character personal code, and use that code for every role you hold.
The legal framework: ECCTA and the Companies Act 2006
The requirement comes from the Economic Crime and Corporate Transparency Act 2023 (ECCTA), which amended the Companies Act 2006 and gave the Registrar of Companies new powers to query, reject and remove information. The aim is to stop people using false or stolen identities to set up and run companies.
Two provisions matter most. Section 1110A of the Companies Act 2006 defines when an individual's "identity is verified": either Companies House has verified it directly, or an authorised corporate service provider has delivered a verification statement. Section 167M then provides that an individual must not act as a director unless their identity is verified, and that the company must ensure this. Breach is an offence by the director, and by the company and every officer in default.
Separate provisions cover PSCs. A PSC who remains registered after their deadline without complying may also commit an offence. The detail sits in regulations and in Companies House guidance, which is updated frequently. Always check the current Companies House guidance on when to verify.
Who must verify, and who comes later
According to Companies House, Companies House identity verification currently applies to:
- directors of UK companies, including directors of overseas companies registered in the UK;
- the equivalent of directors, such as LLP members, general partners and managing officers;
- individuals registered as persons with significant control; and
- authorised corporate service providers (ACSPs), also known as Companies House authorised agents.
Companies House has said it will introduce verification later for people who file on behalf of companies, limited partnerships, corporate directors, corporate LLP members and officers of corporate PSCs. The requirement for filers and agents has been deferred. As reported in August 2026, it is now expected no earlier than November 2027, with at least six months' notice promised.
Shareholders who are not PSCs, company secretaries and employees do not currently need to verify. Our guide to the PSC register explains who counts as a PSC.
Deadlines for directors and PSCs
The 14-day windows and confirmation statement trigger can be confusing, especially for people who hold several roles. The table below summarises the official position.
| Role | When the personal code must be provided | How |
|---|---|---|
| Existing director (in post before 18 November 2025) | With the company's next confirmation statement filed from 18 November 2025 | Confirmation statement filing |
| New director (from 18 November 2025) | At appointment or on incorporation | Appointment or incorporation filing |
| Existing PSC who is also a director of the same company | Within 14 days starting the day after the confirmation statement date | "Provide identity verification details for a PSC" service |
| Existing PSC who is not a director | Within the first 14 days of their birth month | PSC verification service |
| New PSC (from 18 November 2025) | On registration or within 14 days of being added | Registration filing or PSC service |
| Directors of an overseas company's UK establishment | Confirmed by the anniversary of the UK establishment's registration | Overseas company filing |
Two practical points stand out. First, a company cannot file its confirmation statement unless all its directors are verified, so one unverified director can hold up the whole filing. Second, filing a confirmation statement early does not move a director-PSC's 14-day window.
How to verify: One Login or an ACSP
There are only two routes. Do not post or email identity documents to Companies House.
GOV.UK One Login (free)
Most people use the free Verify your identity for Companies House service, which runs on GOV.UK One Login. You can verify with the app, by answering security questions online, or by entering your photo ID details and attending a participating Post Office. Accepted photo ID includes a biometric passport from any country, a UK photo driving licence, and a UK biometric residence permit, biometric residence card or Frontier Worker permit, according to Companies House guidance. Each verified identity must be linked to its own email address.
An authorised corporate service provider
An ACSP, such as an accountant, solicitor or formation agent registered with Companies House and supervised for anti-money laundering purposes, can verify your identity and deliver a verification statement. This route works from any country and suits people without accepted biometric documents or groups verifying many individuals at once. ACSPs may charge a fee. Companies House publishes a list of ACSPs.
Step-by-step compliance plan for a company
For a single-director company, Companies House identity verification is a short task. For a group with many entities, overseas directors and layered ownership, it needs a plan.
- Map every role. List all directors, LLP members and registrable PSCs across the group, noting confirmation statement dates and each PSC's birth month.
- Check PSC entries. Confirm the register is accurate before anyone verifies. Remove PSCs who have ceased and add any who are missing.
- Choose the route for each person. One Login for those with accepted ID; an ACSP for overseas individuals without biometric documents or for bulk verification.
- Collect personal codes securely. Codes can be shared with trusted filers, but treat them like a tax reference. Recommend that ACSP-verified individuals save their code to a Companies House account.
- Diarise the deadlines. Link director codes to the confirmation statement and PSC codes to the correct 14-day window.
- Build it into appointments. Make verification a condition of any board appointment, and of completion on share acquisitions that create a new PSC.
- Keep evidence. Record when each person verified, by which route and when the code was supplied.
Transactions, financings and new appointments
Verification now affects deal timetables. On a share purchase, the buyer's nominees cannot be appointed as directors at completion unless they are already verified, and any individual who becomes a PSC as a result of the deal has 14 days from being added to the register to supply their code. Build Companies House identity verification into the completion checklist and ask incoming directors to verify as soon as heads of terms are agreed.
On the sell side, a buyer's legal due diligence will usually check that the target's confirmation statements are up to date and that every director and PSC has verified. Gaps can lead to specific warranties, indemnities or conditions. See our legal due diligence checklist for the wider review. Lenders take a similar approach on new facilities, often making evidence of verification a condition precedent.
Consequences of non-compliance
Companies House has published its approach to non-compliance with mandatory identity verification. It starts with informing and nudging, but moves to enforcement where those steps fail. A person who misses a due date receives a default letter, and enforcement may follow without further notice.
The main enforcement routes are prosecution, referral to the Insolvency Service and financial penalties. Companies House says non-compliance is likely to be treated as serious if a person or company has committed three or more offences over a five-year period, and it will prioritise cases involving fraudulent documents or criminal activity. Prosecution can lead to fines and director disqualification.
There are practical consequences too. Companies House has said that, in future, it will annotate the public register against unverified individuals, and that they will be unable to be appointed as a new director, register a new company or register as an ACSP. For directors already worried about personal exposure, our guide to directors' duties in the UK covers the wider picture.
Counterparties are already checking. Lenders, investors and acquirers increasingly ask for confirmation that all directors and PSCs have completed Companies House identity verification, and an unverified officer can delay a closing. Treat verification status as a standard item in corporate housekeeping and due diligence.
Illustrative scenario: a UK subsidiary with overseas directors
This scenario is illustrative only and uses generic parties.
A UK trading subsidiary is owned by a holding company in Bangladesh. It has three directors: one in London and two in Dhaka. The holding company is the registrable relevant legal entity, and one individual in Dhaka is also registered as a PSC because of his indirect control.
The London director verifies through One Login in minutes. One Dhaka director holds a biometric passport and also uses One Login. The other has no accepted biometric document, so the company engages an ACSP, which verifies him remotely and delivers a verification statement. The company secretary collects the three personal codes before the confirmation statement date. Because the Dhaka PSC is also a director, he submits his code again through the PSC service within his 14-day window starting the day after the confirmation statement date. The group adds verification to its board appointment checklist so that future directors are verified before their appointment is filed.
Common mistakes and risks
Assuming one filing covers both director and PSC roles
A person who is both a director and a PSC of the same company verifies once but must provide their personal code separately for each role. The director code goes in the confirmation statement; the PSC code goes through the separate PSC service within a 14-day window that starts the day after the confirmation statement date. Many companies file the confirmation statement and assume the job is done, leaving the PSC requirement unmet and the individual potentially committing an offence. Diarise both steps.
Letting an unverified director keep acting
Section 167M makes it an offence for an individual to act as a director without verified identity, and for the company and every officer in default to allow it. Boards sometimes overlook a passive or overseas director who has not engaged. If that person cannot or will not verify, consider whether they should resign or be removed, and document board decisions carefully. Remember too that a company cannot file its confirmation statement until all directors are verified, which can trigger further defaults.
Sharing personal codes carelessly
The personal code links your verified identity to every role you hold. You may share it with people you trust to file for you, such as your accountant or company secretary, but it should be handled like a tax reference number. Companies House can issue a new code if it has been compromised. Never verify on behalf of someone else, and never lend your identity to people setting up companies: Companies House warns that criminals can take on debt in your name and you will be legally responsible.
Mismatched personal details
Codes sometimes fail to connect because the date of birth on the register is wrong, the code was mistyped, or an ACSP supplied incorrect details. Check and correct the date of birth held by Companies House before the deadline, and if an agent verified you, ask them to correct their verification details. Leaving this to the day of the confirmation statement is a common cause of missed deadlines.
Forgetting about PSC birth-month windows
Existing PSCs who are not directors must supply their code within the first 14 days of their birth month. For someone born in, say, January, the window opens on 1 January. Because these dates are personal rather than linked to the company calendar, they are easy to miss in groups with many shareholders. Keep a schedule of PSC birth months and send reminders well in advance; the register shows each PSC's window.
Cross-border groups and overseas directors
Overseas directors and PSCs face the same Companies House identity verification rules as UK residents. Many can use One Login with a biometric passport. Others will need an ACSP, which must be registered with Companies House and supervised by a UK anti-money laundering supervisor. Allow time for document collection, translations and time-zone differences.
When choosing an ACSP for overseas individuals, confirm that it is on the Companies House list, ask which documents it accepts and how it checks them remotely, and agree who will receive the personal code. Companies House sends the code to the email address the ACSP provides, so a wrong address causes delay. Groups with many overseas officers often centralise Companies House identity verification with one agent to keep records consistent.
Foreign companies with a registered UK establishment must confirm that all their directors are verified by the anniversary of the UK establishment's registration. See our guide to registering an overseas company in the UK. Groups expanding from Bangladesh should also read our page on Bangladeshi businesses expanding to the UK.
What to do now
- Confirm that every director has verified and that their code was included in the company's latest confirmation statement.
- Check that every individual PSC has supplied their code in the correct 14-day window.
- Correct any inaccurate PSC entries or dates of birth on the register.
- Make Companies House identity verification a condition of every new appointment and share transfer that creates a PSC.
- Monitor announcements on verification for filers, agents and corporate officers, expected no earlier than November 2027.
TRW & Co's London office, authorised and regulated by the Solicitors Regulation Authority, advises boards and groups on Companies House compliance, PSC analysis and governance. Our corporate governance and company formation teams can help you audit your group and fix gaps. Contact us at info@trw.co or on +880 1779 127165.
Frequently asked questions
01What is the deadline for Companies House identity verification for existing directors?
Directors who were already in post on 18 November 2025 must provide their Companies House personal code as part of their company's next confirmation statement filed from that date. Because confirmation statements are annual, every existing director should have reached their deadline within the 12-month transition period. A company cannot file its confirmation statement unless all its directors are verified, so any unverified director holds up the filing and may expose the company and its officers to offences.
02Do shareholders need to verify their identity with Companies House?
Only if they are registrable persons with significant control. Broadly, an individual is a PSC if they hold more than 25% of the shares or voting rights, can appoint or remove a majority of the board, or otherwise exercise significant influence or control. Ordinary shareholders below those thresholds do not need to verify. Company secretaries do not currently need to verify either, although filers and agents are expected to be brought in later, no earlier than November 2027.
03How long does Companies House identity verification take?
Using the GOV.UK One Login app with a biometric passport or UK photo driving licence, many people can verify within minutes. Verification at a Post Office usually produces a result by email within about a day. Using an authorised corporate service provider depends on the agent's process and how quickly you provide documents. Allow extra time for overseas individuals, mismatched dates of birth and groups with many directors and PSCs.
04Can someone living outside the UK verify their identity for Companies House?
Yes. Overseas directors and PSCs can verify online through GOV.UK One Login if they have an accepted document, such as a biometric passport from any country. If they do not, they can use an authorised corporate service provider, which can verify identities from any country. The ACSP must be registered with Companies House and supervised by a UK anti-money laundering supervisor, and may charge a fee.
05What happens if a director does not verify their identity?
Under section 167M of the Companies Act 2006, an individual who acts as a director without verified identity commits an offence, and so do the company and every officer in default. Companies House will send a default letter and may then prosecute, impose financial penalties or refer the matter to the Insolvency Service, which can lead to disqualification. It has also said it will annotate the register against unverified individuals and block them from new appointments and incorporations.
06Is a Companies House personal code the same as the company authentication code?
No. The company authentication code belongs to the company and authorises online filings. The personal code is an 11-character identifier issued to an individual once they have verified their identity. It is personal to you, not your company, and you use the same code for every directorship or PSC role you hold. You can share it with trusted people who file for you, but you should keep it secure.
Sources and official materials
- Verifying your identity for Companies House — Who must verify, routes and consequences
- When you need to verify your identity for Companies House — Deadlines for directors, PSCs and overseas companies
- Companies House personal codes for identity verification — How personal codes work and are used
- Companies House approach to non-compliance with mandatory identity verification — Enforcement routes and seriousness criteria
- Companies Act 2006, section 167M — Offence of acting as a director without verified identity
- Economic Crime and Corporate Transparency Act 2023 — The Act introducing identity verification
- List of Authorised Corporate Service Providers — Registered ACSPs who can verify identities
General information only, current as at 21 October 2026. It is not legal advice and does not create a solicitor–client relationship. It reflects the law of England and Wales unless stated otherwise; Scotland and Northern Ireland have separate legal systems, and the law changes frequently. Check current official sources and take advice on the facts of your matter.