Companies House identity verification: the transition period is coming to an end
Update
Update
Identity verification became a legal requirement from 18 November 2025 with a 12-month transition period to give companies time to make sure all directors and people with significant control (PSCs) have verified their identity. With the transition period coming to an end, this update summarises the actions that companies should take now, and what happens if the requirements are not met.
Mourant Governance Services (UK) Limited can support clients with navigating the Companies House identity verification requirements, including assisting with the verification process in our capacity as an ACSP. If you have any questions regarding identity verification, your Company’s compliance position or the wider implications of ECCTA, please get in touch with one of the contacts on this page, or your usual Mourant contact.
Introduction
The 12-month transition period for Companies House identity verification is nearing its end. Companies should now check the applicable identity verification deadlines for their directors and people with significant control (PSCs), ensure that those who are required to verify their identity have done so and ensure that the necessary Companies House personal codes are provided for each relevant role by the applicable deadline.
Identity verification became a legal requirement from 18 November 2025 under reforms introduced by the Economic Crime and Corporate Transparency Act 2023 (ECCTA). Companies House introduced a 12-month transition period to allow existing directors, PSCs and companies time to comply with the new requirements.
As that transition period draws to a close, we recommend that companies review their position now rather than waiting until the applicable deadlines approach.
What are the identity verification requirements?
Identity verification is intended to improve the accuracy and reliability of information held on the Companies House register and make it more difficult for individuals to use false or stolen identities when setting up, running or controlling companies.
Since 18 November 2025, identity verification has been a legal requirement for new and existing directors and PSCs, as well as members of limited liability partnerships (LLPs). Requirements for certain other roles are being introduced separately. Companies House currently states that identity verification for people filing at Companies House will be introduced no earlier than November 2027, with at least six months’ notice.
The requirements apply to each relevant role an individual holds. Although an individual will generally only need to verify their identity once, their personal code must then be linked to each relevant company role.
What do existing directors need to do?
For existing directors, verification is linked to the company’s confirmation statement.
An existing director must provide their Companies House personal code and identity verification statement as part of the company’s confirmation statement. Where an individual is a director of more than one company, their personal code must be provided for each company.
Companies House is encouraging individuals to verify as early as possible, and directors can check the Companies House register to establish the identity verification due dates associated with their roles.
What about PSCs?
PSCs are also required to verify their identity and provide their Companies House personal code to Companies House.
The deadline is not necessarily the same as the deadline applying to a director. Each existing PSC has a 14-day period in which to provide their personal code and verification statement. For a PSC who is not also a director of the company, this is the first 14 days of their birth month. For a PSC who is also a director of the company, it is the 14 days starting on the day after the company’s confirmation statement date.
Different deadlines apply to individuals who become PSCs on or after 18 November 2025. Their personal code can be provided when they are first added to the register or within 14 days of being added.
Where an individual is both a director and a PSC of the same company, their personal code must be provided separately for each role. The director requirement is dealt with through the company’s confirmation statement, while the PSC requirement is completed separately using the Companies House PSC service.
Companies should therefore check both roles rather than assuming that providing an individual’s code as a director automatically satisfies their PSC obligations.
Overseas companies with UK establishments
The identity verification requirements are also relevant to overseas companies registered with Companies House that have a UK establishment.
All directors of an overseas company with a UK establishment must complete identity verification and obtain a Companies House personal code. The overseas company must provide the required identity verification details to Companies House, using form OS VS01 unless the relevant information has already been provided. This must be done by the applicable anniversary of the date on which the UK establishment was opened.
Overseas companies with UK establishments should therefore include their directors within their identity verification review and ensure that the appropriate verification and Companies House requirements are completed within the applicable timeframe.
How can an individual verify their identity?
There are two principal routes.
Individuals can verify their identity directly with Companies House using GOV.UK One Login. This service is free and supports a range of identity documents and verification methods. Depending on an individual’s circumstances, alternative routes, including verification at a Post Office, may also be available.
Alternatively, verification can be completed through an Authorised Corporate Service Provider (ACSP).
Mourant Governance Services (UK) Limited is registered with Companies House as an ACSP and can assist clients with completing the identity verification process.
Once identity verification has been successfully completed, Companies House issues the individual with a personal code. The code is important and should be retained securely as it is used to connect the individual’s verified identity with their relevant company roles.
What happens if the requirements are not met?
Failure to comply with the identity verification requirements on time is an offence and may result in enforcement action, including financial penalties or prosecution and a fine. A company will also be unable to file its confirmation statement unless all of its directors have complied with the applicable identity verification requirements. An individual who continues to act as a director after the applicable deadline without complying may commit an offence, and the company may also be committing an offence. Individuals who have not verified their identity may also be prevented from being appointed as a new director or registering a new company.
For PSCs, Companies House may also place a note against the individual’s name on the public register where the verification requirements have not been complied with.
With the transition period now approaching its end, companies should not leave outstanding verification exercises until the last minute.
What should you do now?
We recommend that Companies take the following steps before the transition period comes to an end:
- Review all directors and PSCs associated with the Company and confirm whether they have completed identity verification.
- Check the Companies House register for the relevant verification due dates.
- Obtain and securely retain the Companies House personal codes for individuals who have already verified.
- Ensure each personal code is provided to Companies House for every relevant role held by that individual.
- Arrange verification promptly for anyone who has not yet completed the process.
- For overseas companies with UK establishments, check that all directors have completed verification ahead of the applicable anniversary date.
How Mourant can help
Mourant Governance Services (UK) Limited can support clients with navigating the Companies House identity verification requirements, including assisting with the verification process in our capacity as an ACSP.
Where we provide governance services to your entity, and your directors or PSCs have already completed their identity verification, please provide us with their Companies House personal codes if you have not already done so. This will help us ensure that the relevant information is available when required for future Companies House filings.
For individuals who have not yet verified, we can provide guidance on completing verification directly through GOV.UK One Login or assist with completing the verification through Mourant Governance Services (UK) Limited.
With the transition period running through 17 November 2026, we encourage clients with outstanding verifications to act immediately.
If you have any questions regarding identity verification, your Company’s compliance position or the wider implications of ECCTA, please get in touch with one of the contacts on this page, or your usual Mourant contact.
The information contained in this document is correct as at November 2026. This document is provided for reference purposes only and does not constitute legal, tax, regulatory, accounting, or other professional advice. No part of Mourant provides English legal advice and Mourant Governance Services does not provide legal advice.
Contact
Abiola Motajo
Priscila Santos
This update is only intended to give a summary and general overview of the subject matter. It is not intended to be comprehensive and does not constitute, and should not be taken to be, legal advice. If you would like legal advice or further information on any issue raised by this update, please get in touch with one of your usual contacts. You can find out more about us and access our legal and regulatory notices at mourant.com. © 2026 MOURANT ALL RIGHTS RESERVED
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