Gary Gray: UK directors in spotlight as ID verification deadline looms
Gary Gray
UK companies should urgently check that directors and people with significant control (PSCs) have completed identity verification steps required for each of their roles as the Companies House transition period enters its final months, writes Gary Gray.
New identity verification requirements to help tackle economic crime and to prevent misuse of the UK companies register became mandatory last November and a 12 month transition period ends on 17 November.
Historically, Companies House, which is responsible for incorporating, dissolving, and registering limited companies in the UK, has had no powers to verify the information submitted by companies.
It is now a legal requirement under the Economic Crime and Corporate Transparency Act 2023 (ECCTA) for directors, and individuals who own or control a company – often referred to as “persons with significant control” (PSCs) – to verify their identities with Companies House.
The change is aimed at preventing fraud and providing greater assurance on who is setting up, running, owning and controlling companies in the UK. Directors and those equivalent of directors, such as LLP members and PSCs were among the initial wave of people in-scope of the requirements.
Individuals registering a business as an authorised corporate service provider (ACSP), or Companies House authorised agent, are already required to verify their identity as part of the authorised agent regime. Separate identity verification requirements for individuals who file information at Companies House are expected to be introduced no earlier than November 2027.
Failure to comply by the applicable deadline can constitute an offence and may result in financial penalties or prosecution.It is unlawful for an unverified individual to act as a director after the applicable deadline, and the company will be unable to file its confirmation statement unless all of its directors have complied with the identity verification requirements. Persistent non-compliance could expose individuals and companies to further enforcement action.
There were just over 5.5 million companies on the Companies House register as of June 2026.Companies House has said previously that it estimates that between six and seven million individuals would need to verify their identity by the end of the transition period.
An individual will generally complete the identity check only once. They will then receive a Companies House personal code, which must be used to connect their verified identity to each relevant company appointment or role.
For an existing director, the relevant step will generally need to be completed when the company files its first confirmation statement during the transition period. PSC deadlines depend on the nature of the PSC’s role and the appointed day shown on the Companies House register. Companies should therefore check the register for the due date attached to each individual and each role rather than working from a single group-wide deadline.
This issue is particularly important for corporate groups with numerous subsidiaries, where directors may hold appointments across several entities with different confirmation statement dates.
Group company secretarial teams should map each director and PSC against all current appointments, record the relevant Companies House due dates and ensure that each verified identity is linked to every applicable role. Particular care may be needed for dormant companies, special purpose vehicles and entities outside the group’s routine board reporting cycle.

Gary Gray is legal director, head of governance and company secretarial services, UK, at Pinsent Masons



