Identity verification: new directors’ duties

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) introduced significant reforms to the UK’s corporate regulatory landscape, with a focus on enhancing transparency and combatting economic crime.  

A cornerstone of these reforms is the new requirement for identity verification (IDV) for directors and persons with significant control (PSCs) of UK companies. Evgeni Pratashchyk, corporate solicitor at Lodders, answers the most frequently asked questions about IDV requirements, directors’ responsibilities, practical steps for compliance, and the consequences of non-compliance.

A paradigm shift for Companies House

The ECCTA represents a fundamental change in the way Companies House operates, mandating that individuals involved in the formation, management, and control of UK companies must verify their identity. This measure is designed to strengthen the integrity of the UK’s corporate register and to deter fraudulent activity.

Who must verify their identity?

• Directors of UK companies (including new and existing appointments)
• Persons with Significant Control (PSCs)
• LLP members, general partners, managing officers
• Individuals filing documents at Companies House, whether on their own behalf or for another

When do you need to verify by?

IDV becomes mandatory for new incorporations and appointments of directors and PSCs on 18 November 2025. There is a 12-month transitional period whereby existing directors and PSCs must verify their identity, typically as part of the annual confirmation statement process.

By spring 2026, all presenters of information for Companies House filings must have completed IDV. Company formation agents, solicitors, accountants, and chartered secretaries must be registered as Authorised Corporate Service Providers (ACSPs).

Who is responsible for completing IDV?

It is imperative to note that the responsibility for completing identity verification rests solely with each individual director. Neither the company nor its advisers are responsible for undertaking this process on behalf of directors. Directors must ensure that their identity is verified within the prescribed timeframe to maintain their eligibility to act and to avoid regulatory sanctions.

How do you complete identity verification?

There are two ways that you can complete the IDV process:

1. Online verification via GOV.UK One Login

The GOV.UK One Login portal offers a streamlined, free-of-charge service for IDV, typically completed in approximately 10 minutes. You will need a biometric passport (any country), UK photo driving licence, UK biometric residence permit/card, or UK Frontier Worker Permit, plus additional information such as current and previous addresses. You may also have to answer security questions relating to financial accounts.

Upon successful verification, a unique identity verification number is issued. Directors must retain this number securely, as it will be required for future Companies House filings. As this is a unique reference number personal to you, you will only have to register once even if you a director of multiple companies.

2. Verification via Authorised Corporate Service Provider (ACSP)

As an alternative route, directors unable to use the GOV.UK portal may verify their identity through an ACSP, which is a business or individual registered with Companies House, to file information and verify identities on behalf of clients. Identity check records must be retained for seven years.

What are the consequences of non-compliance with IDV requirements?

Failure to comply with the Companies House IDV requirements may result in:

• Criminal proceedings including potential for prosecution and a level 5 fine
• Civil penalties issued by the Registrar of Companies
• Rejection of incorporation/registration, new company applications may be refused
• Inability to file statutory filings: directors may be prevented from fulfilling statutory obligations
• Public register annotation: individuals may be marked as ‘unverified’ on the public register

Recommended actions for directors

1. Identify which directors and PSCs must complete IDV
2. Ensure all necessary ID documents are prepared and available
3. Complete IDV promptly using the GOV.UK One Login portal or engaging an ACSP as appropriate
4. Retain and safeguard verification evidence such as your unique identity verification number and, if applicable, ACSP records
5. Make a note of deadlines such as confirmation statement dates and transitional periods

Further information and support

For further details, directors are encouraged to consult the official government guidance on how to verify your identity for Companies House and on how to register your business as an ACSP.

Please note: Lodders does not provide identity verification services and cannot complete this process on your behalf. Directors are personally responsible for compliance.

Trusted legal advice

Lodders corporate team helps clients selling and buying businesses typically in the £3-20m deal size range as well as on group reorganisations and related corporate matters. To get in touch, please contact Graham Spalding and Evgeni Pratashchyk at the Business Services group today.