Mandatory Identity Verification at Companies House

Today is a landmark day for UK Company law.  From today, all individual directors, members and persons of significant control (“PSCs”) of UK registered companies and LLP’s (including directors of overseas companies) will be subject to compulsory identity verification, as a result of a series of significant changes introduced by the Economic Crime and Corporate Transparency Act 2023,  brought in in an attempt to improve the accuracy and reliability of the Companies House Register and reduce the risk of fraud.  

Identity can be verified in one of two manners:

1. by registering for a GOV.UK ID and using the GOV.UK ID Check App or web service to complete the process, or face-to-face at a participating Post Office. Further information on this process is available here; or

2. by using a registered Authorised Corporate Service Provider (“ACSP”). Only a limited number of professional service providers, who must be supervised by a UK Anti-Money Laundering supervisory body, are permitted to act as ACSP’s, such as law firms and accountants

Upon verification, individuals will be issued with a “Personal Code”, which requires to be submitted to Companies House in respect of each company of which that person is a director, member, or PSC to confirm their identity has been verified.   It is recommended to keep a precise and secure account of your Personal Code once received.

Identity verification requirements are being introduced on a phased basis for existing companies and LLPs and are mandatory for all new incorporations/appointments.

For existing companies and LLPs, individual directors, members and PSCs who are also directors, will require to verify their identity as and when the company’s annual confirmation statement falls due for filing.  Individual PSCs, who are not also a director of the company of which they are a PSC, will require to verify their identity within 14 days of their birth month, i.e.  if their birthday falls in June, they will require to verify their identity by 14 June 2026.

For new incorporations, individual directors/members will require to be identity verified before the company/LLP can be incorporated.  New PSCs will have 14 days to confirm their identity, commencing from the date on which they are registered as a PSC. New directors have 14 days from appointment to provide their Personal Code to Companies House, and an obligation is placed on the appointing company to ensure that an individual does not act as a director unless their identity is verified.  It is advisable that any new director should not take any actions on behalf of a company in their capacity as director, until their identity has been verified. 

Failure to comply with the new identity verification requirements is a criminal offence, which may result in financial penalty, disqualification or the company being struck off the register.   

Mackinnons, as an Authorised Corporate Service Provider, are dedicated to supporting their clients through these changes, and can verify identity using our secure electronic verification software.  

If you are looking for support on satisfying these new Companies House identity verification requirements, please contact your usual member of our commercial team.  For all new enquiries, please contact our commercial team by email to fionacopp@mackinnons.com, cameron@mackinnons.com and amym@mackinnons.com