Mandatory identity verification - are you prepared?

New mandatory identity verification requirements under the Economic Crime and Corporate Transparency Act 2023 ("ECCTA") are due to come into force on 18 November 2025.

They will be compulsory for individuals who become directors, PSCs or members of LLPs on or after that date. Individuals already in these roles will have a transitional period in which to complete identity verification. Our Corporate team highlights and explores some of the most important points in this article, including key takeaways and recommended next steps.

Key takeaways

All company directors, persons with significant control (PSCs), members of limited liability partnerships (LLPs) and certain others (e.g. individuals filing documents at Companies House) will need to verify their identity.
Identity verification (IDV) started on a voluntary basis on 8 April 2025.
From 18 November 2025, IDV will be mandatory for all individuals who become directors, PSCs and LLP members, regardless of their residency status. For any individual who is already a director, PSC, or LLP member on that date, there will be a transition period in which to complete IDV (which will also apply regardless of the individual’s residency status). Information regarding the applicable deadlines is set out below.
An individual who has multiple roles must have completed IDV by the earliest applicable deadline.
IDV can be completed directly with Companies House (free of charge), or through a Companies House authorised agent - an “authorised corporate service provider” (ACSP) - for a fee.
Individuals who lack the required identity documents or information to complete IDV with Companies House - whether online or at the post office - should consult an ACSP for IDV¹. Others may also choose to use an ACSP for their IDV e.g. for a more managed service.
Once the IDV requirements are in force, if an individual fails to complete IDV and acts as a director or LLP member, they will be committing a criminal offence.
In most cases, IDV will be a one-time requirement.
Once verified, individuals will be given a unique identifier number to use for all their current and future director, LLP member and PSC roles.
Early completion of IDV is advisable to avoid potential delays and fines when the new rules take effect.

Overview

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) introduces significant changes to UK company law aimed at preventing the misuse of corporate structures and combatting economic crime. One key change is the introduction of mandatory IDV, which has been available on a voluntary basis since April 2025.

Companies House has announced that IDV will become mandatory for directors and PSCs from 18 November 2025. Although not explicitly mentioned in the announcement, it is expected that IDV requirements for individual members of LLPs and individual directors of overseas companies with a UK establishment registered at Companies House will also begin on this date.

The IDV requirements relating to limited partnerships, registrable relevant legal entities, corporate directors of companies, corporate members of LLPs, officers of corporate PSCs and individuals filing documents at Companies House will be introduced in due course.

In most cases, individuals will only need to verify their identity once. Upon the successful completion of their IDV, the individual will receive a unique, eleven-digit identifier (known as a 'personal code') from Companies House. This personal code should be kept securely: once the IDV requirements are in force, the individual will need to provide it to Companies House for all their existing and future roles.

If an individual holds multiple roles (for example, as a director of several companies or as a director and a PSC), they must complete IDV before the earliest applicable deadline. They must also submit their personal code to Companies House for each role they hold.

From 18 November 2025, directors and PSCs should be able to check the Companies House register for IDV due dates for their roles.

IDV requirements

These requirements come into force on 18 November 2025.

Directors

Incorporations: Any proposed director of a new company must have completed IDV before the incorporation application is submitted to Companies House.
Newly appointed directors: Any individual appointed as a director of an existing company must have completed IDV before acting as a director and before their appointment is filed with Companies House.
Existing directors: During a 12-month transition period, companies must confirm in their next confirmation statement that all of their directors have completed IDV.

PSCs

Incorporations: The company’s (or LLP’s) incorporation application may include confirmation that the proposed PSC has completed IDV. If it does not, the PSC must complete IDV within 14 days of being added to the Companies House register as a PSC².
New PSC status: When a company (or LLP) notifies Companies House of a new PSC, it may confirm IDV completion. If it does not, the PSC must complete IDV within 14 days of being added to the Companies House register as a PSC³.
Existing PSCs: The timing for completing IDV, and therefore obtaining a personal code, depends on whether the PSC is also a director of the same company⁴:

+ If an existing PSC is also a director of the same company, they must provide their personal code separately for each role they hold: as a director, as part of the company’s confirmation statement, and as a PSC, using a new service, within 14 days of the company’s confirmation statement date.

+ An existing PSC, who is not a director of the same company, will need to provide their personal code within the first 14 days of their birth month. For example, if their birthday is on 26 February, the 14-day period will begin on 1 February 2026.

LLPs

Incorporation: Proposed members must have completed IDV before the LLP incorporation application is filed at Companies House.
Newly appointed members: New LLP members must have completed IDV before acting as a member and before their appointment is filed with Companies House.
Existing members: Existing members of LLPs must complete IDV before the LLP's next confirmation statement date.

Overseas companies with UK establishments

Directors of overseas companies that have registered a UK establishment at Companies House ('overseas companies') must also complete IDV. Directors appointed on or after 18 November 2025 are subject to similar timing requirements to those outlined above. Directors already in office before that date must complete IDV during a transition period expected to run from 18 November 2025 until the first anniversary of the date the UK establishment was opened which occurs after 18 November 2025. Accordingly, for a UK establishment opened on 20 February 2015, the deadline to complete IDV would be 20 February 2026.

How to complete identity verification

Individuals can verify their identity in one of two ways:

1. Directly with Companies House (this service is currently free of charge):

The applicant should access their (or register for a new) GOV.UK One Login account (see here).
The applicant can find out more about the identity verification process and the required documents here.
Accepted IDV documents include a biometric passport from any country, a UK photocard driving licence and a UK biometric residence permit.

2. Through an ACSP (service costs vary depending on the provider)

ACSPs are typically company formation agents, accountants or law firms authorised by Companies House to act in this capacity.
Individuals who lack the required identity documents or information to complete IDV with Companies House - whether online or at the post office - should consult an ACSP for IDV. Others may also choose to use an ACSP for their IDV e.g. for a more managed service.
Not all ACSPs offer IDV services. At present, Stephenson Harwood does not provide such services. However, if you require suggestions of ACSPs that do offer IDV services, or would like further information, please contact your Stephenson Harwood adviser.

Consequences of non-compliance⁵

If an individual fails to complete IDV and acts as a director or member of an LLP, they will commit a criminal offence, punishable on conviction by an unlimited fine (although their actions as director or member will remain valid). Failure to comply with IDV requirements could lead to other consequences, such as, in serious cases, director disqualification.
Companies and LLPs must ensure individuals do not act as directors or members until their IDV is complete. Breach of this obligation is a criminal offence for the company or LLP and for every director of the company or member of the LLP who authorised, permitted, participated in, or failed to take all reasonable steps to prevent, the breach. It is punishable on conviction by an unlimited fine.
Companies and LLPs may face late filing penalties if they are unable to submit their confirmation statement because any of their directors or members have not completed IDV.

Recommended next steps

Check deadlines - note the date of the company’s or LLP’s next confirmation statement on or after 18 November 2025.
Identify everyone who must complete IDV - in particular, directors, LLP members and PSCs.
Encourage early verification - completing IDV during the voluntary window avoids last-minute delays and potential penalties.
Update internal on-boarding processes - incorporate IDV into a company’s or LLP’s standard onboarding process for new directors, LLP members and for PSCs when they assume the role of PSC.
Decide on preferred IDV process - direct with Companies House or through an ACSP.
Secure storage of personal codes - maintain a confidential record for all future filings.

Contact

If you have any questions or require assistance with the IDV process, please contact a member of our corporate finance team or your usual Stephenson Harwood adviser.

The information on the Sites is not intended to address your particular requirements. Such information does not constitute any form of advice or recommendation by us and is not intended to be relied upon by you in making (or refraining from making) any decisions. You should take your own advice.

¹ Accepted IDV documents include a biometric passport from any country, a UK photocard driving licence and a UK biometric residence permit. See further Verify your identity for Companies House.

² According to statute, Companies House will write to the PSC requiring them to complete IDV within 14 days beginning with the date of the direction (s790 LM(2) Companies Act 2006). It is currently assumed that the date of the direction will be the same date as the individual is registered as a PSC at Companies House.

³ Please see footnote 2 above.

⁴ We expect that a similar approach may be taken if a PSC is also a member of the same LLP and is awaiting guidance from Companies House in respect of this.

⁵ There are very limited exemptions to the IDV requirements and are based on national security or crime prevention grounds.

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