Companies House Identity Verification: Half the Register Has Yet to Act and the Transition Ends in November

Every director of a UK company, every member of a limited liability partnership and every person with significant control now has a legal duty to prove to Companies House that they are who they say they are. The duty arrived on 18 November 2025 under the Economic Crime and Corporate Transparency Act 2023, and Companies House allowed a twelve month transition period for the six to seven million people already on the register. That period closes in the middle of November 2026. The figures published at the end of July suggest that a remarkable number of people have yet to act: as at 30 June 2026, only 55 per cent of directors, 50 per cent of LLP members and 42 per cent of PSCs had verified. Roughly four million people had completed the process. Several million had not.

Who must verify, and by when

Anyone appointed as a director, or registered as a PSC, on or after 18 November 2025 must already have verified. A new director cannot be appointed, and a new company cannot be incorporated, without the personal code that verification produces. A new PSC has fourteen days from registration to provide theirs.

For those already in office before that date, the deadline is personal to the company rather than fixed by the calendar. An existing director must verify, and supply their personal code, when the company files its next confirmation statement. Companies House has been clear that the statement cannot be filed at all unless every director has done so. A company whose confirmation statement date falls this autumn therefore has weeks rather than months, and a director who leaves the task until the statement is due may find the filing blocked.

PSCs follow a slightly different route. A PSC who is also a director of the same company must provide their code twice: once in the confirmation statement as a director, and once through the separate PSC service within a fourteen day window that opens the day after the confirmation statement date. A PSC who is not a director must provide their code within the first fourteen days of their birth month. Each role is linked to the verified identity separately, and completing one does not complete the other.

How verification works

There are two ways to verify. The first is directly with Companies House through GOV.UK One Login, which is free. Most people use the app with a biometric passport, a UK photocard driving licence or a biometric residence permit. Those who cannot use the app may answer security questions instead, or attend a Post Office in person with their documents. The second route is through an Authorised Corporate Service Provider, which is an accountant, solicitor or formation agent registered with Companies House for the purpose. A provider must check identity to the same standard as Companies House itself and may charge a fee.

Whichever route is taken, the result is a Companies House personal code of eleven characters. The code belongs to the individual, not to any company. One code serves every directorship and every PSC interest a person holds, now and in the future, and it must be quoted each time a new appointment is filed. It is not shown on the public register and should be treated with the care one would give a bank PIN.

What happens to those who do nothing

The consequences are not merely administrative. It is a criminal offence to act as a director without having verified once the duty bites, and the company and every one of its officers commit an offence too where an unverified director continues to act. Companies House has described a staged approach to enforcement. During the transition its emphasis has been on reminders and guidance. After it, the unverified will find themselves unable to file statutory documents, including the confirmation statement, or to take up new appointments or incorporate new companies. Civil financial penalties follow, with a public annotation against the name on the register, and prosecution is reserved for deliberate evasion. Persistent breach may lead to disqualification proceedings. The Companies House business plan for 2026 to 2027 commits the registrar to bringing every company into compliance, or into enforcement, by the end of the financial year.

The annotation deserves a moment's thought. Lenders, insurers, landlords and prospective buyers all read the register, and a note recording that a company's directors have failed a basic legal duty is not the impression a well run business wishes to leave.

What was postponed in August

Companies House had intended to extend verification to everyone who files documents, and to require every third party agent filing on a company's behalf to be a registered Authorised Corporate Service Provider, from November 2026. In early August 2026 it announced that both measures are deferred to no earlier than November 2027, with at least six months' notice before they take effect. That is welcome breathing space for agents, but it changes nothing for directors, LLP members and PSCs, whose deadlines stand exactly as they were.

Practical points

The first task is to find the company's confirmation statement date, because that is the real deadline for its directors and its PSC directors. The second is to verify now rather than in the week the statement is due: a Post Office appointment or a provider's checks take time, and a director abroad, or one whose passport has lapsed, will need longer still. The third is to remember that each role is linked separately, so a person who is both director and PSC must complete both steps, and a person with several companies must link the same code to each. The fourth is to keep the code safe and share it only with those trusted to file on the company's behalf.

The reform is, at heart, a simple one. A public register of companies is only as trustworthy as the identities recorded on it, and for years that trust was misplaced. Verification takes most people a few minutes. The cost of leaving it undone is measured in blocked filings, penalties and a permanent mark against one's name.

Dr Aamir Nawaz