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Jurisdicta
The review of where business is established, licensed and banked.
Issue 002Sunday 18 October 2026The Rulebook
Issue 002 · The Rulebook · United Kingdom

Companies House identity checks: the transition for existing companies is ending

Identity verification for directors and people with significant control has been compulsory since 18 November 2025. The 12-month transition for existing companies runs out next month, and UK subsidiaries managed from abroad are the most likely to miss it.

Sunday 18 October 20264 min readChecked against 8 official sources
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In one minute
What changedIdentity verification for directors and people with significant control has been compulsory since 18 November 2025. The 12-month transition for existing companies runs out next month, and UK subsidiaries managed from abroad are the most likely to miss it.
Who is affectedEvery director and individual PSC of a UK company is affected, wherever they live.
Key date18 November 2026On our calculation the period ends on 18 November 2026.
What to doBefore 18 November 2026, and in any case before your next confirmation statement, check that every director and individual PSC of each UK subsidiary has verified and that the company holds their personal codes.
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Identity verification for directors and people with significant control (PSCs) of UK companies became a legal requirement on 18 November 2025, under changes made by the Economic Crime and Corporate Transparency Act 2023. In a press release first published on 5 August 2025, Companies House said that existing directors must confirm their verification when the company files its next confirmation statement, within a 12-month transition period, and that existing PSCs must verify within 12 months of 18 November 2025. On our calculation the period ends on 18 November 2026. GOV.UK does not give that date as such: the government's campaign page says 18 November 2025 "is not a deadline" and that people must verify "by their due dates".

What the rules say

Directors, PSCs and members of limited liability partnerships must verify, as must directors of overseas companies registered in the UK. Corporate directors, corporate LLP members, officers of corporate PSCs, limited partnerships and people who file on a company's behalf will be brought in later.

There are two routes. The first is the free Verify your identity for Companies House service, which runs on GOV.UK One Login. GOV.UK says a biometric passport from any country can be used to verify online with the app; the bank details and Post Office routes are described only for people who live in the UK. The second route is an Authorised Corporate Service Provider (ACSP), an agent registered with Companies House and supervised for anti-money laundering purposes, which may charge a fee. GOV.UK says an ACSP can be based in any country.

A successful check produces a personal code of 11 characters. The code belongs to the individual, not the company, and is used for every role they hold. GOV.UK advises keeping it secure and sharing it only with people you trust, such as an accountant who files for you.

Timing depends on the role. An existing director gives the code in the company's next confirmation statement, and a company cannot file that statement unless all its directors are verified. An existing PSC who is not a director must provide the code within the first 14 days of their birth month. A PSC who is also a director verifies once but supplies the code separately for the PSC role, within 14 days starting the day after the confirmation statement date. New directors give the code on appointment or incorporation, and new PSCs within 14 days of being added to the register.

Who is affected

Every director and individual PSC of a UK company is affected, wherever they live. That includes the UK subsidiaries of groups based in the UAE, Mauritius or the Seychelles, whose directors are often abroad and whose filings are handled by an agent. Those directors are treated in the same way as UK-resident ones: they verify through One Login with a passport, or through an ACSP, and the company files their codes.

Where the registered PSC is the overseas parent company rather than an individual, Companies House said, in reply to a comment on its blog, that there are "currently no identity verification requirements" for such legal entities. Requirements for officers of corporate PSCs will follow later.

Key dates

  • 8 April 2025: voluntary verification opened.
  • 18 November 2025: verification became a legal requirement.
  • 18 November 2026: end of the 12-month transition, on our calculation from 18 November 2025.

What it means in practice

Failing to verify on time may be an offence, leading to prosecution, a fine or a financial penalty, and continuing to act as a director or PSC after the deadline without complying may also be an offence. GOV.UK warns that a note may in future appear against the person's name on the public register, and that they may be barred from new appointments or registrations.

Consider a hypothetical UK trading subsidiary owned by a Dubai holding company, with two directors in Dubai, one in Port Louis and a confirmation date in November 2026. Each director needs a personal code before the confirmation statement is filed, or the filing will fail. The parent, as a corporate PSC, does not verify. If a founder is also registered as an individual PSC, the founder's deadline turns on their birth month, not on the company's calendar.

Overseas companies with a UK establishment follow a separate rule: GOV.UK says they must confirm that all directors have verified by the anniversary of the establishment's registration.

What we do not yet know

Companies House has not given a date for the later stages covering corporate directors and officers of corporate PSCs. Nor does GOV.UK say which non-UK documents an ACSP may accept; that is left to the ACSP, which decides what evidence it needs.

What to do nowBefore 18 November 2026, and in any case before your next confirmation statement, check that every director and individual PSC of each UK subsidiary has verified and that the company holds their personal codes.
Our readingUK subsidiaries of Gulf and Indian Ocean groups are often run at a distance, with the filings left to an agent. The most likely way these groups will meet the new regime is a confirmation statement that fails because one director abroad has no code.
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This piece appeared in Jurisdicta, Issue 002. General information only; not legal, tax or investment advice.

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