Detailed look into ID Verification for Directors.

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) has been bringing some major changes impacting companies into force since it was enacted. One of the key aims of ECCTA is to crack down on the misuse of companies by criminals and, to that end, ECCTA is introducing mandatory identity verification (IDV) for all directors of companies and Persons with Significant Control (PSCs). Voluntary IDV using the Companies House route opened on 8 April 2025 and some Authorised Corporate Services Providers (ACSPs) have already started providing IDV services as well.

This article sets out the rules on IDV, the ways IDV can be done, the consequences of failing to do so and some practical advice for companies.

For an overview of this information, please read our previous blog on ID verification for directors.

The rules on IDV

Directors

Under the ECCTA, all directors of UK companies will need to have their ID verified in order to act as a director. Directors of UK establishments of overseas companies will also be subject to the IDV regime. From the date on which the IDV rules come into force – which is currently stated to be autumn 2025 – every director will have to have their ID verified by one of the methods specified by the IDV regulations, as set out below.

For existing directors, IDV will need to have been successfully completed by the date the company's first confirmation statement is due after the rules come into force. For example, if the IDV rules come into force in October 2025, directors of companies which file their confirmation statements on 15 December will need to have had their ID verified before the confirmation statement is filed in December.

We believe that a director's IDV status will not, at least when the rules first come into operation, automatically flow to all their other directorships, meaning a director will need to confirm their IDV status on the first confirmation statement for each company of which that person is director, once the IDV rules come into force. It is likely that the Companies House systems will be adapted to link IDV status to all a person's directorships in the future.

Anyone who becomes a director of a UK company for the first time, from autumn 2025 (or whenever the IDV rules come into force) will have to have had their ID verified before their appointment is notified to Companies House and before they can act as a director. This also applies to incorporations of new companies which will not be possible unless the first directors of the new company have had their ID verified.

The IDV will, in the vast majority of cases, be a one-off requirement and will not need to be repeated when, for example, a passport is renewed. Companies House will be able to ask a director to re-verify their ID in circumstances where they suspect, for example, that the evidence presented is false.

PSCs

All individual PSCs will be required to have their ID verified, in the same way as directors, once the IDV rules come into force. Where the PSC is a relevant legal entity ("RLE") – such as another UK company – a "relevant officer" of the RLE, such as a director, must have their ID verified.

On incorporation, any individual PSC of the new company will have to provide IDV to Companies House within 14 days and, where the PSC is an RLE, the relevant officer will have to verify their ID within 28 days of incorporation.

It is not yet clear by what date existing PSCs will have to have their ID verified as the company itself is not responsible for ensuring IDV of its PSCs, unlike for its directors, and so may not be required to confirm IDV for PSCs on their confirmation statements after autumn 2025. Companies House may instead issue notices requesting that PSCs verify their identity during the year's transitional period after IDV becomes mandatory or there may be a date by which all PSCs or relevant officers of RLEs will need to have complied with the IDV rules. This will be clarified when the IDV regime comes into force.

Persons filing at Companies House

At some point in 2026, the ECCTA will require anyone making Companies House filings to have their ID verified in order to do so. Alternatively, filing can be done through an ACSP; Brodies will have ACSP status in order to file for clients at Companies House.

There is no firm date for when these parts of the ECCTA will come into force in 2026 and Companies House has recently changed its estimate from spring 2026 to spring/summer 2026.

How to get your ID verified

Through Companies House

Voluntary IDV via Companies House is now open and, for anyone with a biometric passport from any country, this is the easiest and cheapest way to verify ID. In our experience, it can be done in around five minutes.

Individuals can verify their ID through Companies House for free using the GOV.UK One log-in system, either in the app or on the website. It will also be possible for people who live in the UK and who don't have the necessary biometric evidence to verify their ID in person at the Post Office.

In order to use the Companies House IDV service, people must:

have access to the internet;
have an email account that has not previously been used for anyone else verifying their ID;
be a registered user of Companies House Services - this is simply a log in to use Companies House rather than an account used to make filings: and
have the required information and evidence to support their application for IDV (see below).

When verifying ID via Companies House, you must provide the following information:

an email address not being used by anyone else to verify ID, meaning that bulk IDV carried out by one person using a single email is not possible;
your home address (proof of address will be needed if you have lived at the address for less than 12 months);
your full name; and
your date of birth.

Individuals also need to present documentary evidence of ID such as a biometric passport, issued by any country in the world, a UK driving licence or a UK frontier worker or residence permit. To see the full list of evidence which can be used, you can access the regulations.

The IDV is linked to a credit check and using a UK driving licence involves answering security questions linked to the credit check.

If you are using the app or the website, your personal code, which is an 11 digit code, will be displayed on the screen at the end of the verification process. The code is not being sent by email so it would be sensible to take a screenshot or photograph of the personal code and retain it safely. You will also be able to find your personal code in the ‘manage account’ section of your Companies House account, although this may not be immediate, in our experience.

Through an ACSP

The other way for people to have their ID verified is via an ACSP, which is offering IDV services. The person will need to supply the ACSP with the information set out above, including an email address not used to verify anyone else's ID, plus documentary evidence. The range of documentary evidence which an ACSP can accept for IDV is wider than that accepted by Companies House.

There are already some company secretarial firms who have registered as ACSPs and are providing IDV services, such as Elemental and Vistra. They will charge for the service - £150 and £165 respectively - but for people from countries which don't issue biometric passports, such as South Africa or India, or who don't have the necessary evidence to use the Companies House route, this will be the only option.

The service should be swift and simple to use and the ACSP will confirm that IDV is complete. The Companies House personal code will be emailed to the person's email address rather than to the ACSP.

ID status on the Companies House Register

At the moment, it is not certain how IDV status will be shown on the Register but we know that Companies House will have to indicate whether or not IDV has taken place, at least once the transitional year for existing directors and PSCs to complete their IDV is over. The IDV statement an ACSP has to make will appear on the Register as well.

Consequences of failure to have ID verified

Directors

Under the ECCTA, it will be a criminal offence, punishable by a fine, for a director who has not had their ID verified to act as a director. The company will also be committing a criminal offence if it allows its directors to act as such without IDV and all officers of the company could be subject to criminal fines.

Persistent breaches of the Companies Act are a ground for disqualification under section 3 of the Company Directors Disqualification Act 1986 (as amended by the ECCTA) so there is a possibility that a director who persistently fails to have their ID verified, or re-verified if directed by Companies House to do so, could be disqualified. At this stage, no guidance has been issued on whether Companies House will seek to disqualify directors who fail to have their ID verified.

The ECCTA makes it clear that failure by a director to have their ID verified will not invalidate acts of that director so a director whose ID is unverified will still be able to bind the company and a third party will be able rely on acts done by that director, such as entering into contracts. The ECCTA does not therefore intend to alter the legal position regarding a director's capacity and validity of acts done by them. Directors who have not had their ID verified can continue to exercise the powers to manage the company and any functions delegated to them under the constitution. However, a director who acts as a director while unverified will be committing a criminal offence.

It is likely that market practice will develop in relation to dealing with companies whose directors are not all ID verified and counterparties such as banks and other financial institutions may refuse to deal with companies with unverified directors. Counterparties may not accept documents which have been executed by directors with unverified ID.

PSCs

It will not be the responsibility of the company to ensure its PSCs are ID verified and companies will not be subject to any sanctions where their PSCs have not complied with the ECCTA IDV rules. However, the company can supply the IDV details of their PSC(s) and full IDV compliance for PSCs by all companies is desirable.

Action for companies to take now

Ensure that every director is aware of the need to have their ID verified and of the document(s) they will require to produce to do so.
Identify any directors who will not be able to use the Companies House route and organise for their ID to be verified by an ACSP.
Although the mandatory rules are not yet in force, it would be sensible to encourage every director to have their ID verified in the next few months.
If directors are using the Companies House route, suggest they note their personal code from the screen or take a screenshot/photograph and give it to the person in the company who is responsible for Companies House filings, if relevant.
When appointing directors in future, make them aware that they must have their ID verified before they are formally appointed, if they have not already done so.
Make your HR and company secretarial teams aware of the new regime so they can adapt any documentation accordingly.
Inform your PSCs of the IDV requirements and ask them to complete the necessary IDV, including identifying who will be the relevant officer for PSCs which are UK companies.

For more information on ID verification under the ECCTA, please get in touch with the authors or one of our corporate lawyers.