Mandatory identity verification to commence on 18 November 2025 

The Economic Crime and Corporate Transparency Act 2023 introduced the concept of mandatory identity verification (IDV) for all UK companies as well as UK limited liability partnerships (LLPs). Companies House has now announced that the roll out of this IDV process will commence on 18 November 2025 and will take place over a 12-month period. Whilst IDV is not mandatory at this time (we are currently in a “voluntary” phase), it will be important to take early compliance steps to avoid the serious implications of non-compliance.  

Who needs to verify their identity? 

From 18 November 2025 

• New directors and LLP members will need to verify their identity first before the company or LLP is incorporated and before their appointment to an existing company or LLP. 

• Existing directors and LLP members will need to verify their identity by the time of filing of the next confirmation statement from 18 November 2025. If a person is a director or member of more than one company/LLP, then it is the filing of the earliest confirmation statement which mandates when identity verification should take place.  

• Newly notified persons with signification control (PSCs) of companies and LLPs also need to verify their identity within a 14-day period of their registration at Companies House. Existing PSCs will need to be identity verified within 14 days of an “appointed day” and which differs depending on their circumstances. If a PSC of a company is also a director of the same company they must complete IDV within 14 days of the company’s confirmation statement date. If a PSC is not a director of the same company they must complete IDV within 14 days from the first day of their month of birth as shown on Companies House records (e.g. if the date of birth is 22 January then the 14 day period begins on 1 January). It is anticipated that similar time frames will also apply to PSCs of LLPs.   

Implications of failure to comply 

An individual who fails to complete IDV within the relevant timeframe will commit a criminal offence. In those circumstance directors of companies and members of LLPs are prohibited from acting in that capacity for the relevant company/LLP until the IDV is completed. Importantly, a company or LLP will also itself commit an offence if a director or LLP member continues to act when their identity has not been verified in the relevant timeframe. Companies/LLPs are not liable for the non-compliance of their PSCs.  

Ways to identify identity 

There are two routes to IDV 

• Via Companies House: this is a free of charge service and will require individuals to go through the GOV.UK One Login which will then direct the individual to verify their identity online either via the mobile  phone app route or web browser route. The individual will need to provide identity evidence such as biometric passport, UK photo driving licence or UK biometric residence permit. More information can be found on the Government site Verify your Identity for Companies House.    

• Using an Authorised Corporate Service Provider: you can ask a registered Authorised Corporate Service Provider (ACSP), also known as a Companies House authorised agent, to verify a person’s identity. Various corporate governance/ compliance entities are set up to provide this service and will charge a fee per individual they IDV. ACSPs can often co-ordinate the IDV of a group of named individuals and report back to a key contact on progress; for some entities this may be a useful add-on service.  

What happens when a person has completed IDV? 

Once a person has successfully verified their identity, Companies House will issue them with a unique identifier number (otherwise known as a “personal code”) which they should keep safe and only disclose in limited circumstances. Evidence of this personal code will be key for certain Companies House filings. In due course we also anticipate that the Companies House registry will be annotated in some way to indicate that a person’s identity has been verified although the personal code itself will not be disclosed. 

Future requirements 

Companies House has explained that the identity verification of persons making filings at Companies House, limited partnerships, corporate directors of companies, corporate members of LLPs, officers of corporate PSCs (otherwise known as relevant legal entities) will commence at a later date. 

What you need to do now 

It will be important to complete the following steps now: 

• ensure relevant individuals are aware of the IDV requirements 

• decide how you wish to proceed with IDV: (i) using the free of charge Companies House service, or (ii) using as ACSP to manage this process. 

We strongly recommend that individuals commence IDV in the current voluntary period and before compliance becomes mandatory from 18 November 2025.