Identity verification

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.

Identity verification is due to become mandatory in autumn 2025. Once in force:

• New directors and PSCs (including relevant officers of RLEs) will need to be verified upon:
  • Incorporation of a new company; and
  • Appointment of a new director/notification of a new PSC.
• Existing directors and PSCs will have a 12-month transition period in which to confirm that they have verified their identity. Companies will need to provide ID verification information for their directors and PSCs in their first confirmation statement due, following the start of the transitional period (in autumn 2025).

Individuals can voluntarily verify their identity now. We recommend that current directors of companies with confirmation statements due in autumn 2025 should take action over the summer to verify their identity before the mandatory regime kicks in, to avoid coming under pressure as the filing date approaches.  

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.

Once the regime becomes mandatory, a director should not take any actions on behalf of the company until their identity is verified. Continuing to act as a director without being verified will amount to an offence committed by the company and every officer in default punishable by a fine; although, importantly, the actions undertaken by the director will not be invalidated. Directors who persistently act without having been verified may also face disqualification.

We have considerable expertise on the new legislation and guidance on identity verification.  We will be happy to support you in ensuring that the right people in your business have had their identity verified, including practical help in selecting which method of identity verification would suit your circumstances and how to complete the necessary steps.

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.