Overview
The Economic Crime and Corporate Transparency Act 2023 (ECCTA) introduced an identity verification (IDV) regime which effectively requires certain individuals involved with UK registered companies, UK registered limited liability partnerships (LLP), and limited partnerships (LP), to have their identities verified.
When is this coming into force?
Voluntary IDV started on 8 April 2025.
The legal requirement to verify identities is expected to come into force later this year (expected Autumn 2025).
Companies House published timeline and guidance suggests that:
- By autumn 2025, IDV will be mandatory for directors and PSCs on new company incorporations and for new directors and PSCs of existing companies.
- By autumn 2025, a 12-month transitional period will begin, requiring existing directors and PSCs to verify their identity as part of the annual confirmation statement process.
- By spring 2026, only an ID-verified officer or employee of a company, or an ACSP (or its officers or employees), will be able to file a document at Companies House on behalf of a company.
Who needs to verify?
The following individuals will need to verify their identity:
- a new or existing director of a UK registered company;
- a new or existing person with significant control (PSC);
- a new or existing member of a LLP;
- a new or existing general partner (GP) of a LP;
- a managing officer who is the equivalent of a director;
- a relevant officer of a PSC that is a Registrable Legal Entity (RLE);
- a director of an overseas company required to register a UK establishment at Companies House; or
- someone who makes Companies House filings for a company – for example, a company secretary.
How can you verify?
There are three ways that individuals can verify their identity – these are:
- Directly with Companies House Online via GOV.UK One Login - With the GOV.UK ID Check app, documents such as a UK photocard driving license, UK passport, a non-UK passport with a biometric chip, a UK biometric residence permit, UK biometric residence card, or UK Frontier Worker permit can be used. The security questions that will have to be answered online cover things like the individual's mobile phone contract, and any bank accounts, credit cards, loans, or mortgages that they may have. In addition, details will be required from either a UK passport, a UK photocard driving license or a current account with a UK bank or building society;
- In person at a Post Office - If using the Post Office, the individual will need to enter details from their photo ID on GOV.UK and then go to a Post Office that offers 'in branch verification' services where they'll scan the photo ID and take a photo of the individual. Only a UK passport, non-UK passport, UK photocard driving license, European Union (EU) photocard driving license, national identity photocard from an EU country, Norway, Iceland, or Liechtenstein will be accepted as photo ID; or
- Using an Authorised Corporate Service Provider (ACSP) – ACSPs are individuals or organizations such as company formation agents, solicitors, accountants, chartered secretaries, and governance professionals who have registered as ACSP's with Companies House. ACSPs will also be known as Companies House authorized agents. IDVs carried out by ACSPs must meet the same level of assurance as those who verify directly with Companies House.
Corporate directors are expected to be abolished under ECCTA soon. However, once in force, there will be an exception to this rule whereby a corporate entity registered in the UK will be able to be a director of a UK company provided that:
- the corporate entity has a legal personality;
- each of the corporate entity's directors is a natural person; and
- each of the corporate entity's directors has had their identity verified.
Once an individual or an organization has had their identity verified, Companies House will issue a personal code as evidence of their IDV.
What should you be doing?
At this time, you should be reviewing your company/ group structure, identifying, and notifying all the persons (i.e. their PSCs, directors, members, etc.) that will be affected by the new IDV regime ahead of the expected compliance deadlines.
It is important to ensure that Companies are adequately prepared and that relevant persons are notified of the upcoming requirements so that they are aware of the changes, their responsibilities under the new rules and are ready to meet the deadlines and provide their passports, driving licenses and other relevant documents.
We suggest that you audit your records to ensure that the information held by the company in relation to its directors, members and PSCs is accurate and up to date.
You should also consider whether any relevant individuals should verify their identities voluntarily now or at least starting the process to ensure that future compliance deadlines are not missed.
What happens after?
Once an individual's identity has been verified, Companies House will issue them with a unique identifier number, which will need to be included on filings at Companies House when IDV becomes mandatory. Directors, for example, will need to provide this code when a confirmation statement is filed or when they are appointed.
Individuals will usually only need to undertake the verification process once, even if they hold multiple directorships and are also PSCs.
Consequences for non-compliance
There will be consequences for people who do not comply with the identity verification requirements - in the form of both criminal sanctions and civil penalties for the director/member or PSC/RLE as well as the company. The Companies House register will also be annotated to reflect where someone has an unverified status which will be publicly available and may have consequences if any searches are carried out against the individual and the company. An individual whose identity has not been verified will be unable to be appointed as a director.
If you have any questions in respect of new IDV regime or require any assistance please do not hesitate to contact Michael Thompson (mthompson@steptoe.com), Sonia Mohammed (smohammed@steptoe.com) or Shreena Patel (smpatel@steptoe.com).
