The UK is poised to implement a substantial reform in corporate governance with the introduction of mandatory identity verification for company directors and persons with significant control (PSC). Effective from 18 November 2025, these requirements, enacted under the Economic Crime and Corporate Transparency Act 2023, represent a decisive move to enhance the integrity and transparency of the UK’s company register.

Background 

Historically, the process for appointing directors and PSCs to UK companies has not required formal identity verification. This absence of scrutiny has, unfortunately, facilitated the appointment of fictitious or fraudulent individuals, undermining the reliability of the register and exposing UK companies to misuse and economic crime.

The new regime seeks to address these vulnerabilities by ensuring that only verified individuals may act as directors or PSCs. This reform is part of a broader governmental initiative to strengthen the UK’s reputation as a safe and transparent jurisdiction for business. 

By mandating identify verification, the government aims to:

• Deter fraudulent activity and the misuse of UK companies;
• Enhance the reliability and trustworthiness of the corporate register;
• Support law enforcement efforts in combating economic crime; and
• Align the UK with international standards of transparency and anti-money laundering.

Key changes and requirements

For existing company directors and PSCs:

• Existing company directors and PSCs must verify their identity from 18 November. There will be a 12-month transition period once the changes come into force, but directors and PSCs must ensure ID is verified prior to the filing of the company’s next confirmation statement.
• The equivalent of a director, such as members, general partners and managing officers will be required to verify their identity.
• Those that file for a company, such as a company secretary, will also be required to verify their identity.

For new companies and appointments:

• From 18 November 2025, you will not be able to incorporate a new company until identity verification has been completed for all proposed directors, company secretaries and/or PSCs.
• Filings to appoint any new directors or PSCs will not be accepted after this date until identity for all new appointments have been verified.

It is important to note that requirements for limited partnerships, corporate directors, and officers of corporate PSCs will be introduced at a later stage.

Methods of verification

Directors and PSCs may verify their identity through one of the following methods:

Online via GOV.UK One Login:
This secure digital service utilises biometric passports, UK driving licences, or other approved identification documents. Upon successful verification, the individual’s personal code will be accessible via their Companies House account. This method is a free of charge option and is suitable for most UK-based individuals with standard identification documents. The process is streamlined and straightforward for those that do not require additional support.

Authorised Corporate Service Provider (“ACSP”):
Verification may be conducted by an ASCP which includes solicitors accountants, estate agents and any other organisation who is supervised by a UK anti-money laundering body. The ACSP will issue the personal code by email upon completion of the process. This can be a more appropriate method to verify identity, for those individuals who might benefit from professional guidance and would require tailored support in complex cases, such as multinational or high-risk scenarios.

What happens once you have verified?

Once you have successfully verified your identity, you will receive a unique Companies House personal code. The code will be personal to you, and will be required for several governance activities such as filings confirmation statements, appointments as a director, or when you may become a PSC. The same personal code can also be used where an individual is a director or the equivalent of a director, for multiple corporate structures. 

Existing directors will need to ensure they share their code with Companies House by submitting a verification statement for each company role held from 18 November 2025, before the filing of the next confirmation statement of each relevant company. Carrying out this step will ensure Companies House can link your verified identity to their records.

Similarly, PSCs are required to provide their personal code to Companies House within a 14-day period, the timing of which depends on their registration status before 18 November and whether they also serve as directors of the company.

Compliance and Consequences

Failure to comply with the new requirements will have significant consequences. Companies will be unable to file confirmation statements unless all directors have completed the verification process. Directors continuing to act in their role without verifying their identity after it becomes a legal requirement will be committing an offence and the Company and all directors may also be committing an offence. Equally, any PSCs acting in their role after the new requirements take effect may also be committing an offence. The consequences of failing to meet the new requirements may result in regulatory penalties, reputational harm, and the potential loss of directorships.

Directors and PSCs are strongly advised to initiate the verification process promptly and to ensure that all personal and company details held by Companies House are accurate and up to date. 

Particular attention should be paid to the consistency of dates of birth and other identifying information, as discrepancies may impede successful verification. 

Individuals who have previously verified their identity must still provide their personal code and verification statement for each role held.

For further advice on this and other Corporate & Commercial issues, please contact Chris Brightling, Caroline Armitage, Jonathan Masucci, Elesha Bradford, Sarah Karam or Mathew Blatchford-Horn.