Companies House confirms mandatory identity verification from 18 November 2025 – what businesses need to know

Posted: 02/09/2025

Companies House has confirmed that compulsory identity verification (IDV) will be phased in from 18 November 2025. This is a key milestone in the implementation of the Economic Crime and Corporate Transparency Act 2023, which aims to strengthen the integrity of the UK's corporate registers and reduce fraud.

Who must verify?

Since April 2025, individuals have been able to voluntarily verify their identity. From 18 November 2025, IDV will be mandatory for company directors, LLP members and persons with significant control (PSCs).

Most individuals will be able to complete IDV directly with Companies House via the free GOV.UK One Login service. If individuals are unable to satisfy the documentation requirements for this service, they will need to engage an authorised corporate service provider (ACSP) to verify their identity. For further details on the IDV process, see our article here.

IDV is a one-off requirement (subject to limited exceptions). Verified individuals will receive a personal code that will also be linked to any other roles held (eg directorships), however individuals must complete IDV by their first applicable deadline.

What are the deadlines?

Incorporations and new appointments

• Incorporations – individuals will need to have completed IDV to incorporate a company. Incorporations without a verified director (and equivalent) will be rejected by Companies House. 
• Appointments – directors will need to verify their identity within 14 days' of appointment to an existing company and submit their personal code to Companies House. It is an offence for an individual to act as an unverified director. Equivalent measures will apply for LLPs.

Businesses should therefore ensure that individuals complete their IDV (if they have not already done so), in advance of their appointment.

Existing directors and LLP Members

Existing directors will need to provide their personal IDV code as part of the company's next annual confirmation statement filing. Practically, directors will need to have completed IDV in advance of this. Equivalent measures will apply for LLP members.

Consequently, IDV compliance will be particularly pressing for businesses due to file their annual statements in the coming months.

Persons with Significant Control

The deadlines for PSCs to complete IDV and submit their personal code to Companies House will depend on their circumstances.

• If an individual is both an existing PSC and director of the company (and equivalent for LLPs):
  - as a director, they will need to confirm they have completed IDV and provide their personal code when the company's next annual confirmation statement is filed at Companies House; and
  - as a PSC, their IDV confirmation and personal code will need to be submitted within 14 days of the company's confirmation statement date, using a new Companies House service which will be available from 18 November 2025.
• If an individual is an existing PSC but not a director of the company (and equivalent for LLPs) – they must provide their IDV confirmation and personal code within the first 14 days of their birth month as shown at Companies House. For example, if their birth month is shown as February 1980, the 14-day period to notify Companies House will start on 1 February 2026.
• If an individual becomes a PSC on or after 18 November 2025 – new PSCs will need to submit their IDV confirmation statement and personal code within 14 days from the date they are registered as a PSC at Companies House.

Overseas companies with UK establishments

Individual directors of overseas companies with UK establishments (OSUK) will need to verify their identity, irrespective of whether they are involved in the UK business. It is expected that mandatory IDV will also apply from 18 November 2025, with slightly modified deadlines.

• Registration and appointments – an individual appointed as a director will need to verify their identity before registering the UK establishment at Companies House. Similarly, for appointments to an existing OSUK, individuals will need to complete IDV before their appointment is notified to Companies House. Until their identity is verified, they must not act as a director of the OSUK while in the UK.
• Existing directors must have completed IDV by the first anniversary of the OSUK being opened, once mandatory IDV begins (for example, if the OSUK was registered on 10 June 2014, the deadline will be 10 June 2026).

Future IDV requirements

Mandatory IDV will be introduced at a later date for: people who file at Companies House; limited partnerships; corporate directors of companies; corporate members of LLPs; and officers of corporate PSCs (also referred to as relevant legal entities or 'RLEs').

It is worth noting, however, that if these corporate directors, members or RLEs are UK companies or LLPs themselves then their underlying individual directors/ LLP members will still need to complete IDV in advance of the next annual confirmation statement date for their respective entity.

Impact on businesses

The introduction of mandatory IDV may have several operational implications for businesses:

• Delays to company formations and transactions – corporate incorporations without verified directors (and equivalent) will be rejected by Companies House. Likewise, new appointments to existing entities will be unable to act unless they have completed IDV. In turn, this could also delay time-sensitive transactions or restructurings if IDV is not planned in advance.
• Increased administrative burden – businesses will need to track the IDV verification status for all relevant individuals, ensuring compliance by the applicable deadlines. This may require updates to internal governance procedures and record-keeping systems.
  Mandatory IDV is being introduced at the same time as changes to the maintenance of company registers, meaning businesses will need to engage with a fast-changing compliance landscape within a relatively short period of time – click here to read more.
• International role-holders - foreign individuals and those based outside the UK may face additional challenges in using the GOV.UK One Login system or engaging ACSPs, potentially affecting governance arrangements.
• Risks of non-compliance – individuals who fail to complete IDV will commit a criminal offence, as will companies with an unverified director (and every officer of the company). Similar measures will apply to LLPs and OSUKs. In addition to fines, non-compliance may also result in:
  - unverified individuals being restricted from submitting filings at Companies House;
  - corporate registers being publicly annotated as non-compliant (which could, for example, impact on insurance and finance availability); and
  - disqualification proceedings for unverified directors with a history of persistent breaches.

Preparation is key

Businesses should familiarise themselves with the IDV reforms and assess the impact of the changes on their boards and any wider group structures. Particular areas include:

• Identifying which role-holders will need to complete IDV and mapping out relevant compliance deadlines.
• Raising awareness at board level and among PSCs (including any pressure points created by the timings outlined above).
• Considering how the IDV process will be managed, including:
  - if individuals will be encouraged to verify directly or if an ACSP will be engaged;
  - for large/complex businesses, whether the IDV process will be managed in stages.
• Ensuring individuals have the necessary documents to complete IDV (these should be up-to-date and include accurate details).
• Updating onboarding processes to ensure new directors/LLP members complete IDV and provide their personal codes in a timely manner.

For a detailed guide on the range of corporate reforms, including key considerations for businesses, click here.  

Companies House has launched a dedicated website outlining the changes. A range of factsheets is also available here. If you have any concerns about the reforms or would like to discuss their impact in more detail, please contact our specialist corporate team. We will be monitoring developments and providing further updates in due course.

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