Identity verification became a legal requirement on 18th November 2025 with a “transition year”, designed to let existing directors, LLP members and people with significant control verify at a sensible point in their own filing cycle. As of June 2026 figures released by Companies House less than half of the Directors, LLP members and PSC’s on the register had done this and whilst this may now well ave risen it is likely lots still need to do it, noting enforcement for not registering has already begun (small fines thus far to individuals, these could increase and people could be disqualified as Directors and not allowed to set up further company’s etc).
Who has to verify and by when?
Despite this “transition year” there is no single date that applies to everybody. The timing depends on the role the “individual” holds.
- Existing directors and LLP members: must verify their identity and their personal code must be provided with the company’s next confirmation statement dated on or after 18th November 2025.
- Existing PSCs who are not also directors of the same company: their window is not tied to the confirmation statement at all! It runs for 14 days starting from the first day of their month of birth. So a PSC born in November has a window that opens on 1st November 2026 and closes 14th November 2026.
- People who are both a director and a PSC of the same company: the confirmation statement route governs, with the PSC element sitting in a 14 day period beginning the day after the confirmation statement date.
- New appointments: anyone appointed as a director since the rules commenced must already be verified before the appointment is notified (so these should be done already)
The PSC side is complicated (compared to a simple “transition year” as touted) and no doubt is why the enforcement action so far has largely been re PSC’s being late in verifying their identity.
Consequences of getting it wrong
Failing to verify when required is not just a “admin issue”. Acting as a director without having verified is an offence under the Economic Crime and Corporate Transparency Act, and Companies House has a financial penalty regime it can apply, alongside its power to annotate the public register. An annotation is visible to lenders, insurers and counterparties, which for many owner-managed clients is not going to be appreciated! There is also a very ordinary commercial consequence that if a code is missing or has not been correctly linked to the individual’s record, the confirmation statement will not go through and, if the confirmation statement does not go through, the company drifts towards default and the register shows it.
Possible action plan
- Extract every director, LLP member and PSC across your corporate client base. Include the recorded month of birth for PSCs, because that is what drives their window.
- List those that are not yet shown as having “verified” and check when they need to be verified (should have verified maybe!)
- Contact those clients to remind them of what needs to be done and how you can help them with it (e.g. advise them through the process or offer IDV services as a registered ACSP).
