One of the key reforms to company law being brought in by the Economic Crime and Corporate Transparency Act 2023 (ECCTA) is the requirement for directors and Persons with Significant Control (PSCs) to have their identity verified. We have previously written about the implementation timetable for the ECCTA as well as key points for companies. Anyone who already is a director and people becoming a director of a company for the first time will have to go through an identity check. Individuals who are PSCs, or relevant officers of a company registered as a PSC, will also have to undergo ID verification checks. This is part of the Government crackdown on economic crime and is a significant shift in practice for UK companies.
More detail on how to verify ID and on timing has been published recently.
Timing
Since we last wrote about the possible timetable for implementation, a firm date of 8 April 2025 has been set for voluntary IDV checks. From this date, directors and PSCs can voluntarily verify their ID in a number of ways and the Government has recently given more detail on what is needed to do this.
IDV through Companies House
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; and
- have the required information and evidence to support their application for IDV (see below).
There are three options for people using the Companies House ID verification route, all through the GOV.UK One Login system; using their ID check app, the web service or face to face at a Post Office (having booked a slot through the One Log-In website).
To have their ID verified, applicants will need to provide:
- their name (and any former names);
- date of birth;
- current home address (and, if required previous addresses); and
- an email address that hasn't been used by anyone else to verify their ID.
They will also need to provide evidence of their identity, such as a bio-metric passport, driving licence or resident permit, from The Registrars’ (Identity Verification by the Registrar) Rules 2025 list.
Using the Companies House ID verification service is free of charge and will be straightforward for holders of bio-metric passports or driving licences.
IDV through an Authorised Corporate Service Provider (ACSP)
ID verification can also be done through an ACSP, such as a company secretarial firm, accountant or law firm. Applications to become an ACSP can be made from 18th March and it is not clear how long that process will take so it may be that the Companies House route is the only one available when voluntary ID verification starts on 8 April.
Not all firms that become ACSPs will necessarily provide ID verification services and those that do are more than likely to charge for them.
After the ID check
Following a successful ID check, a director will be issued with a unique identifier number which will be used for all their director appointments, both current and future.
Unless Companies House requires a director to have their ID re-verified at a later date, this ID verification should be a one-off process.
Action to take
Companies should make sure all their directors know about the IDV requirements and ask them to check they have the necessary documentation for ID verification.
Directors and individual PSCs would be well advised to voluntarily verify their ID at Companies House as soon as IDV checks open on 8 April 2025 so they are ready to meet the ID verification requirements in advance of the company's next confirmation statement, in which they will need to confirm that their IDs have been verified.
It is key that people who have successfully completed an IDV check – whether through Companies House or an ACSP - retain their unique identifier number securely and, if appropriate, share it with the person in the company who does Companies House filings.
For more information on ID verification under the ECCTA, please get in touch with one of our corporate lawyers.
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