Compulsory ID checks for company directors are coming: are you ready?
Julian Lomas
New legal requirements have been introduced for identity verification of company directors, persons of significant control (PSCs) and people who file for a company with Companies House.
From 8 April 2025, it is now possible to choose to verify your identity as a company director or PSC but it will become a legal requirement from autumn 2025. At some point in the future it will also be compulsory for anyone filing for a company at Companies House to verify their identity.
Anyone who has not verified their identity will not be able to file for a company at Companies House or start a new company and, within 12 months of it becoming a legal requirement, anyone continuing to act as a director without verifying their identity will be committing a criminal offence (resulting in a fine) and could be disqualified from acting as a director or PSC (which will also mean they would be disqualified from acting as a charity trustee).
This means that all companies need to get ready for the identity verification process, including charitable companies and CICs. This does not apply to registered charities that are not a company (such as a Charitable Incorporated Organisation - CIO).
Company directors and PSCs can verify their identity with Companies House, either online using their gov.uk One Login, in person at a Post Office or with an Authorised Corporate Service provider (ACSP) such as an accountant or solicitor registered with a UK Anti-Money Laundering supervisory body. To do this you need a biometric passport from any country, a UK photo driving licence, a UK biometric residence permit, a UK biometric residence card or a UK Frontier Worker permit.
We have already verified identities for the directors and PSCs of our company and we have discovered that the online system is not as straightforward as you might hope. There are particular complications if you have a Companies House account with a different email address to your gov.uk One Login. Therefore we recommend doing this early.
Once a person has verified their identity with Companies House they will receive a unique identifier known as a Companies House Personal Code. The code is personal to them, not the company. As far as we can tell, that code is only provided on screen (if you verify online). It is not emailed to the person and there appears to be no way to ask for it a second time. So keep a safe record of your code.
From autumn 2025, when a company files its confirmation statement, it will need to provide the unique code for each of its directors and PSCs. Similarly, if a new director or PSC is appointed, the code will be needed for that person when filling the appointment with Companies House. Remember that in both cases you only have 14 days to file, so make sure you have the details before making an appointment and well before the confirmation statement filing window.
To find out more about the governance support and training we offer, including help with Trustee and Board development, please contact us at julian@almondtreeconsulting.co.uk to arrange free initial telephone discussion.