The ECCTA aims to increase transparency and accuracy by introducing identity verification for individuals who are:
company directors;
members of LLPs;
a nominated director of any corporate member of an LLP or corporate general partner of an LP;
registrable PSCs;
relevant officers of companies that are RLEs; and
anyone who delivers documents to Companies House on their own behalf or on behalf of another.
Mandatory identity verification for directors and individual PSCs came into force on 18 November 2025. The relevant regulations provide for a 12-month transition period commencing on that date, in which directors, individual PSCs and members of LLPs can verify their identity, and Companies House be notified accordingly. The timings for the transition period are set out below. Identity verification requirements for limited partnerships, corporate directors of companies, corporate members of limited liability partnerships (LLPs), and officers of corporate PSCs will commence at a later date.
| Category | Timing for identity verification | Verification Trigger |
|---|---|---|
| New Directors / LLP members | From 18 November 2025 onwards | At point of incorporation of a new entity or appointment to an existing entity |
| New PSCs | From 18 November 2025 onwards | Within 14 days of registration as PSC with Companies House |
| Existing Directors / LLP members | The first confirmation statement date falling within the 12‑month transition period (beginning 18 November 2025) | Confirmation statement date |
| Existing PSCs who ARE Directors / LLP members | Within 14 days following the first confirmation statement date falling within the 12‑month transition period (beginning 18 November 2025) | Confirmation statement date |
| Existing PSCs who are NOT Directors / LLP members | During the 12‑month transition period (beginning 18 November 2025), within 14 days of the first day of the month in which they were born (for example, if someone has a birthday on 20 December, they have 14 days beginning on 1 December 2025 to verify their identity). | First day of the month in which their birthday lands |
There are two routes for verification:
Companies House verifies an individual’s identity directly through the GOV.UK One Login web channel or app, or face-to-face at the Post Office; or
an authorised corporate service provider makes a statement confirming that it has verified an individual’s identity (S&B will not be providing this service).
Directors of companies and individual members of LLPs are prohibited from acting unless their identity has been verified. The prohibition does not take effect until after the deadline for filing the first confirmation statement that falls due after 18 November 2025. After this point, continuing to act as a director or member without being verified constitutes an offence committed by the relevant entity and each of its officers which is punishable by a fine; although, importantly, the actions undertaken by the director or member will not be invalidated. Directors who persistently act without having been verified may also face disqualification.
Our specialist company secretarial team looks after client companies by way of annual retainer. To explore how we can support you with this service, please contact lucy.barnes@stevens-bolton.com.
