Date updated: Wednesday 15th January 2025
Companies House will be introducing a new identity verification process under the Economic Crime and Corporate Transparency Act 2023 (“ECCTA”). These changes are planned to take place from Autumn 2025, with existing companies, directors, and persons of significant control (“PSCs”) to have a 12-month transition period to verify their identity with Companies House.
The below is an overview of what is expected to be required, so that you can prepare yourself for these changes.
The following people will be subject to mandatory identity verification rules:
all new and existing company directors (including shadow directors);
all new and existing PSCs;
all members of limited liability partnerships (“LLPs”);
partners of limited partnerships; and
anyone incorporating a company or filing information at Companies House on behalf of themselves or a company or LLP.
Identity verification will be completed either:
directly with the government using the GOV.UK One Login; or
through an Authorised Corporate Service Provider (ASCP) – these will be organisations authorised by Companies House to file on behalf of clients and registered with a supervised UK body for anti-money laundering purposes, like solicitors and accountants.
We understand that it is likely the verification with Companies House will be a digital process and will require a smart phone and an identity document. Further details should be provided following publication of the secondary legislation.
Once the measures come into force, there is expected to be a 12-month transitional period, during which existing directors, PSCs, and members of LLPs will have to verify their identity with Companies House.
For new directors and PSCs, the time frames for verifying their identity with Companies House (or an ACSP) will be as follows:
New directors will be required to verify their identity prior to acting as a director. There will be a prohibition on acting directors whose identity has not been verified, and companies will be required to ensure that an individual does not act as a director until the person has been verified (although, it will not impact the validity of an individual’s acts as a director prior to identification);
New PSCs will have a 14-day period in which to verify their identity (measured from the date on which the company notifies Companies House of a PSC), and new relevant legal entities (“RLEs”) will have a 28-day period to confirm a director of the RLE with a verified identity (measured from the date on which the company notifies Companies House of the RLE).
For anyone filing information on behalf of a company or LLP or on their own behalf, from spring 2026, the individual must be verified before they are able to deliver a document to Companies House (unless they are an ACSP or an employee or officer of an ACSP). If an individual is filing on behalf of a company, they will need to confirm that they are an officer or employee of the company. This means that, for group companies, a group Company Secretary will not be able to file on behalf of another entity within the group unless they are also an officer or employee of the company in question and their identity is verified.
Once the new measures have come into force, non-compliance will be an offence, and every officer guilty of an offence in England and Wales will be liable to a fine.
If you would like to discuss this matter further, please contact Tamsin Eastwood, Partner and Head of Corporate and Commercial.
This document is for guidance only. The law and practice referred to has been paraphrased or précised and should not be construed or relied upon as legal advice. Please do not treat anything enclosed as legal advice or act on the information provided without first taking professional advice on your particular situation.