Companies House reforms: preparing for new identity verification requirements

Posted: 21/03/2025

Companies House has published further details on one of its key reforms under the Economic Crime and Corporate Transparency Act 2023: the introduction of identity verification (IDV) from 8 April 2025.

This article outlines the IDV process, anticipated timings to comply and how businesses can prepare for the new requirements.

Process

As detailed in our guide to the reforms, the IDV regime captures all new/existing directors (and equivalent, eg LLP members), all persons with significant control (PSCs) and anyone submitting filings to Companies House (among others).

From 8 April 2025, individuals will be able to voluntarily verify their identity directly with Companies House via the GOV.UK One Login service, using one of three channels:

• the ID Check app, using photo ID (eg UK passport) and completing a facial scan;
• the web portal, by completing security questions online; or
•  in person at a Post Office offering in-branch verification (also requiring photo ID).

Individuals will need to provide certain details (including a valid email address) and documentation, outlined further on the One Login webpage and Registrar’s Rules 2025.

While it is envisaged that most individuals will be able to verify directly via the free One Login service, there will be some limitations: for instance, the web portal will only be available to individuals with UK documentation. Likewise, all three channels will require at least one form of biometric evidence.

If individuals are unable to satisfy the documentation requirements for direct verification, they will need to engage an authorised corporate service provider (ACSP). 

IDV is expected to be a one-off requirement. Verified individuals will receive a unique code that will also be linked to any roles (eg directorships) held in other businesses.

Beware of non-compliance

Individuals who fail to complete IDV will commit a criminal offence, as will companies with an unverified director (and every officer of the company). Similar measures will apply to LLPs.

In addition to fines, non-compliance may also result in:

•  unverified individuals being restricted from submitting filings at Companies House;
• corporate incorporations without verified directors (and equivalent) being rejected;
• the company register being publicly annotated as non-compliant (which could, for example, impact on insurance and finance availability); and
• disqualification proceedings for unverified directors with a history of persistent breaches.

Timelines in context

Looking ahead, the Companies House outline transition plan indicates that, by autumn 2025, IDV will become compulsory on incorporations for new directors and PSCs.

For existing directors and PSCs, a transitional period will kick-in and they will have until the company’s next confirmation statement to complete the IDV process; in practice, for many businesses this may result in a short timeframe for the relevant individuals to become compliant.

Timings are also compounded as Companies House expects that, by spring 2026, individuals submitting filings will need to have completed IDV.

Consequently, preparation will be key and businesses may wish to consider taking advantage of the lead-time created from April 2025 for individuals to voluntarily verify their identities.

How to prepare

Businesses should familiarise themselves with the reforms and assess the impact of the changes on their boards and any wider group structures. Particular areas include:

•  raising awareness at board level and among PSCs (including any pressure points created by the timings outlined above);
• considering how the IDV process will be managed regarding directors/LLP members and PSCs, including:

o   if individuals will be encouraged to verify directly or if an ACSP will be engaged;

o   for large/complex businesses, whether the IDV process will be managed in stages;

• ensuring individuals have the necessary documents to complete IDV (these should be up-to-date and include accurate details); and
• considering processes to ensure directors/LLP members complete IDV in a timely manner when appointed.

For a detailed guide on the range of corporate reforms, including key considerations for businesses, click here.  

Companies House has launched a new website outlining the changes. A range of factsheets has also been published (available here). If you have any concerns about the reforms or would like to discuss their impact in more detail, please contact our specialist corporate team. We will be monitoring developments and providing further updates in due course.

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