What do academy trusts need to know about the Companies House identity verification and company register changes?

Who will need to verify their identity?

The following people will be subject to mandatory identity verification rules:

• all new and existing company directors – for academy trusts this would include the directors (i.e. the trustees) of the academy trust, as well as the directors of any trading subsidiary of the academy trust); and
• all new and existing individual PSCs – this will only be relevant to those academy trusts which have PSCs. Many academy trusts do not have PSCs but for those that do, this will also need to be considered.

In future, anyone filing any information at Companies House on behalf of themselves or a company – for example a company secretary and/or governance professional of an academy trust that files information at Companies House on behalf of the academy trust will also be subject to identity verification rules. There will also be identity verification requirements relating to RLEs, to verify the identity of registered officers of a company which is a RLE (so if the academy trust has an RLE or the academy trust is itself an RLE there will be further identity verification requirements regarding the authorised officer of that RLE).

What does the identity verification process look like?

Identity verification can 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.

If the GOV.UK service is used, the person will need a One Login account, details of their current address and an ID document, for example a passport or a driving licence. There is also the option to verify identity face to face at a Post Office or by answering some security questions online if the person lives in the United Kingdom. As an alternative, an ACSP can be used to verify identity on someone’s behalf.  

Once identity has been verified, the person will be provided with a Unique Identifier which will be personal to that person and can be used to connect their verified identity to the Companies House record for each role that they hold. In most cases, they will only need to verify their identity once and the Companies House register will be updated with any changes. 

The identity verification process is already live and directors and PSCs do not need to wait until the rules become mandatory to start the identity verification process. Academy trusts (and any trading subsidiaries of academy trusts) will want to ensure that their directors and (where relevant) PSCs are already familiar and starting to undertake this process in advance of the changes becoming mandatory.

What are the timeframes for identity verification?

From 18 November 2025:

• a person who becomes a new director of a company will need to provide their Unique Identifier as part of their appointment filing at Companies House (or if it is a new company as part of the incorporation information);
• a person who becomes a new PSC will need to provide their Unique Identifier within 14 days of being added to the Companies House Register;
• existing directors will need to provide their Unique Identifier in the company’s first confirmation statement after 18 November 2025;
• existing PSCs, who are also directors of the same company, need to provide their Unique Identifier (i) as part of the company’s first confirmation statement after 18 November 2025 for their role as director and (ii) within 14 days of the confirmation statement date for their role as PSC (there will be a separate service for this); and
• existing PSCs, who are NOT also directors of the same company, need to provide their Unique Identifier within 14 days of their birth month (e.g. if the individual is born in December, this would need to be provided within 14 days of 1 December), again via a separate service.

Once the new measures have come into force, it will be an offence to not comply with the new rules, and every officer guilty of an offence in England and Wales will be liable to a fine.

Compulsory identify verification is also being introduced for anyone filing information on behalf of a company at Companies House, with further verification requirements also following regarding corporate directors and RLEs and their authorised representatives – the implementation date for these requirements has not yet been published. 

The government guidance on ID verification can be found here.

In addition to the changes to the ID verification, from 18 November 2025 there are also changes to the statutory registers which a company is required to hold and maintain. These are sometimes known collectively as the “Company Books” and are registers which a company is required to hold at its registered office, single alternative inspection location (SAIL), or if the company has elected to do so, on a central register held at Companies House.

From 18 November 2024 companies will no longer need to hold the following registers:

• register of directors;
• register of directors’ residential addresses
• register of secretaries; and
• register of persons with significant control.

Companies are still required to register this information with Companies House though and keep this updated.

From 18 November 2025, companies will though still be required to hold a register of members and this will need to be kept either at the company’s registered office address or at a SAIL (it can no longer be held on a central register at Companies House). If an academy trust has previously elected to hold their register of members at Companies House, the academy trust will need to create and maintain a register of members at the registered office or SAIL. The register should include a statement making clear that before the change, the information on members was held on the “central register”.

Further information on the changes to the statutory registers is available on Companies House here.

• Start planning now for 18 November 2025 – check who needs to be verified and when, review your statutory registers and diarise relevant deadlines.
• Make sure your directors (and if relevant) PSCs are aware of the ID process and the need to verify their identity and the relevant deadlines.
• Ask directors/PSCs to start the voluntary ID verification process now, so that when compliance is mandatory the academy trust is prepared.
• Ensure you have processes to collect and store the Unique Verification codes. Make sure the codes are collected in time for the mandatory filing requirements.
• Update any internal policies/processes to account for ID verification, for example, any relating to the appointment/resignation of trustees.
• Review your company statutory registers – if the academy trust has elected to hold the members register on the central register at Companies House, a register of members will need to be created and maintained at the registered office (or SAIL).
• Don’t forget (if relevant) your trading subsidiaries – ensure these are also prepared and ready.
• Look out for further changes – for example, the ID requirements for persons filing at Companies House on behalf of an academy trust, and the ID requirements relating to the PSC regime for RLEs and their authorised representatives.