For decades, setting up and running a limited company in the UK required almost no proof of identity. A name, an address, and a company name were enough. You could appear on the Companies House register as a director of multiple businesses without ever having to demonstrate that you were who you claimed to be. It was one of the reasons the UK ranked consistently among the world's easiest places to incorporate — and one of the reasons UK companies became vehicles of choice for financial crime, money laundering, and corporate fraud.
The Economic Crime and Corporate Transparency Act 2023 changed that. From 18 November 2025, the identity of every director, every Person with Significant Control, and every person filing documents at Companies House must be verified. A new system of Personal Codes — unique, permanent, 11 digit alphanumeric identifiers issued to each individual after successful verification — links the person to every company they are associated with on the register.
The verification regime has been live for nearly five months. New directors are required to verify before their appointment is filed. Existing directors and PSCs have until 18 November 2026 to complete verification.
At CoreAcc Accountants, we are a registered Authorised Corporate Service Provider, which means we can verify directors and PSCs on behalf of our clients and report the verification directly to Companies House. This article explains everything you need to know about the requirement, the process, the consequences of failure to comply, and how we can help.
Disclaimer: This article is for general information only and does not constitute legal advice. Always seek specific advice for your individual circumstances.
1. The Background: Why This Change Was Necessary
The Economic Crime and Corporate Transparency Act 2023 is the most significant reform of UK company law in a generation. It was driven by a series of high profile reports that documented the extent to which Companies House had become, in the words of one parliamentary report, "a filing service rather than a checking service." Any name could appear as a director. Any address could be listed as a registered office. Dissolved companies could be recreated with similar names to legitimate businesses. And because Companies House operated on a register and check model — filing first and investigating later — fraudulent entries could remain on the register for months or years before being challenged.
The identity verification regime is one part of a broader package of reforms that also includes enhanced investigation powers for Companies House, the ability to query and reject suspicious filings, new rules on registered office addresses, and the forthcoming changes to accounts filing and transparency discussed in other articles on this hub.
The stated objective of identity verification is straightforward: every person appearing on the Companies House register in a responsible capacity must be who they claim to be. This does not prevent legitimate business from being conducted through a UK company. It simply ensures that anyone doing so can be identified.
2. Who Must Verify and When
Existing directors and PSCs
If you are currently a director of any UK company or LLP, or a Person with Significant Control of any UK entity, you must complete identity verification by 18 November 2026. This deadline applies regardless of how long you have been a director and regardless of whether your company is trading actively or is dormant.
The obligation is triggered by your company's Confirmation Statement. Specifically, your identity must be verified before your company files its first Confirmation Statement after 18 November 2025. For many companies, this means the deadline is the anniversary of their last Confirmation Statement — which varies by company. For most, it will fall somewhere between now and November 2026.
If your company's Confirmation Statement is due in, say, September 2026, you need to be verified before that filing date. If your company's statement is due in January 2027, it needs to be filed after 18 November 2026 and you must be verified before it is submitted. In practice, the cleanest approach is to verify now rather than waiting for your individual deadline to approach.
New directors being appointed from 18 November 2025
For any director appointed on or after 18 November 2025, verification must be completed before the appointment is filed with Companies House. There is no grace period for new appointments. Attempting to file an appointment for an unverified individual will result in the filing being rejected.
This has practical implications for company formation. Anyone incorporating a new company or adding a new director from the date the regime went live must either verify the director directly through GOV.UK One Login before filing the appointment, or use an Authorised Corporate Service Provider who can carry out the verification and include the verification reference in the filing.
PSCs who are not directors
A Person with Significant Control who is not also a director has the same fundamental deadline — verification by 18 November 2026 for existing PSCs, or before any filing is made regarding their PSC status for newly notified PSCs. The verification obligation is linked to any filing that involves their details, not just to the Confirmation Statement cycle.
Multiple company directors
One of the most important features of the Personal Code system is that verification is personal, not company specific. Once you have verified your identity and received your Personal Code, that code follows you permanently. If you are a director of five companies, you verify once and link your Personal Code to each company's filings. You do not repeat the verification process for each company.
3. The Verification Process: Two Routes
Route one: GOV.UK One Login
The first verification route uses the government's GOV.UK One Login system and is designed for individuals who have a smartphone and a biometric identity document — typically a passport with a chip, a biometric residence permit, or a UK driving licence.
The process involves downloading the GOV.UK ID Check application, scanning your biometric document using your phone's NFC capability, and completing a facial recognition check — a "selfie" that is compared to the photograph on your document. The system verifies that the document is genuine and that the person holding the phone matches the document, and then issues a confirmation through GOV.UK One Login.
Once verified through GOV.UK One Login, you link your verification to your Companies House account and your Personal Code is generated and associated with your details on the register.
The GOV.UK One Login route is free, can be completed entirely from your smartphone, and typically takes less than fifteen minutes where the document scan is successful. However, it does require a compatible smartphone, a biometric document, and a willingness to submit to facial recognition. For some individuals — those without compatible devices, those without biometric documents, or those who have specific privacy concerns about facial recognition — the second route is more appropriate.
Route two: Authorised Corporate Service Provider
The second verification route uses a registered Authorised Corporate Service Provider. An ACSP is an organisation that has been registered with Companies House to carry out identity verification on behalf of individuals and report the result directly to the register. To become an ACSP, an organisation must be regulated by one of a list of approved supervisory bodies — these include ACCA, ICAEW, CILEX, the Law Society, and others.
CoreAcc Accountants is registered as an Authorised Corporate Service Provider. This means we can verify your identity using acceptable identity documents in a face to face or remote setting, complete the verification process on your behalf, and report the result to Companies House — resulting in your Personal Code being issued without you needing to use the GOV.UK app or submit to automated facial recognition.
The ACSP route is particularly useful for:
Directors who do not have a compatible smartphone or biometric document. We can verify using a broader range of acceptable documents including documents that are not machine readable.
Overseas directors who are unable to complete the GOV.UK One Login process due to technical limitations with the app in certain countries. We provide remote verification services for directors based outside the UK.
Directors and PSCs who prefer to have the process managed professionally, particularly where multiple individuals in a company structure need to be verified simultaneously.
Company formations where the speed and certainty of ACSP verification is preferred over the GOV.UK self service route, which can occasionally produce technical difficulties with document scanning.
4. The Personal Code: What It Is and How It Works
Once verification is complete, Companies House issues an 11 digit alphanumeric Personal Code to the verified individual. This code is permanent — it does not expire and is not renewed. It follows the individual throughout their business life regardless of how many companies they are associated with, how their personal circumstances change, or how many times they move address.
The Personal Code must be included in any filing that involves the individual — director appointments, PSC registrations, and Confirmation Statements. Companies House uses the code to link the individual's verified identity to every company filing, creating a permanent audit trail.
The code is not publicly visible on the Companies House register. It appears in the internal records linked to the verified individual but is not displayed to anyone searching the register from outside. What is visible is the verified status — a positive indicator showing that the person's identity has been confirmed.
Where an individual's verification has not been completed, the register will display an unverified status flag against their name. This is a significant compliance marker that is visible to anyone searching the register — including banks, lenders, suppliers, and customers.
5. The Consequences of Failing to Verify
The consequences of failing to verify by the applicable deadline are serious and escalate over time.
The filing blockade
The most immediate practical consequence is that your company will be unable to file documents at Companies House where those documents involve an unverified director or PSC. The Confirmation Statement cannot be submitted. Director appointments, resignations, and changes cannot be processed. The company's register will become outdated and eventually overdue.
An overdue Confirmation Statement triggers a series of Companies House enforcement actions, beginning with warning letters and progressing to the company being flagged as potentially dissolved. In extreme cases of persistent failure to comply, the company can be struck off the register.
The public unverified flag
Companies House will mark unverified directors and PSCs visibly on the public register. This flag is a significant reputational and commercial risk. Banks carrying out standard Know Your Customer checks on businesses they deal with will see the unverified status. Lenders evaluating credit applications will see it. Suppliers and customers conducting due diligence will see it. The unverified flag signals that the individual in question has not completed a basic legal requirement — and for many commercial counterparties, this is sufficient to pause or decline a business relationship.
Criminal offences
Acting as a director without having verified your identity when required to do so is a criminal offence under the Economic Crime and Corporate Transparency Act 2023. The maximum penalty is a fine. The offence is not merely administrative — it is a criminal matter that can result in a conviction appearing on a director's record. Persistent failure to comply, or failure to comply in the context of wider corporate misconduct, can lead to prosecution rather than a civil penalty.
Director disqualification
The Insolvency Service, which administers director disqualification proceedings, treats persistent failure to comply with Companies House obligations as a relevant factor in disqualification assessments. A director who repeatedly fails to comply with legal filing requirements — including identity verification — faces the risk of a disqualification order preventing them from acting as a director for a period of up to 15 years.
6. Overseas Directors
The identity verification requirement applies to all directors of UK companies, regardless of where they are based. A director living in the United States, France, the UAE, or anywhere else in the world must verify their identity in the same way as a director based in the UK.
The GOV.UK One Login route has limitations for overseas directors. The GOV.UK ID Check application may not be available in all countries, and the NFC chip reading capability may not function correctly with all non UK biometric documents. For directors based overseas who cannot complete the self service route, the ACSP route is the appropriate mechanism.
CoreAcc Accountants manages identity verification for overseas directors through our remote verification service. We request acceptable identity documents, carry out verification against an approved standard, and report the result to Companies House on the director's behalf. This ensures that overseas directors meet their legal obligations without needing to travel to the UK or navigate the technical limitations of the GOV.UK app from abroad.
7. Corporate Directors
One element of the ECCTA reforms that has been delayed is the expected restriction on corporate directors — companies acting as directors of other companies. The original plan was to prohibit corporate directors entirely, with an exception for companies with an all natural person board. This prohibition has been postponed and is not yet in force.
Where corporate directors continue to exist, the obligation to verify falls on the natural persons who are themselves the directors of the corporate director. The verification requirement therefore reaches through the corporate layer to the human beings ultimately responsible. Companies with corporate director structures should take specific advice on how the verification requirement applies to their specific arrangement.
8. Worked Examples
Worked Example 1: An Existing Director Using the GOV.UK Route
Sarah is the sole director of a marketing consultancy. The company's next Confirmation Statement is due in August 2026. She has not yet verified.
She downloads the GOV.UK ID Check application on her iPhone. She enters her GOV.UK One Login credentials. She scans the NFC chip in her passport using her phone, and completes the facial recognition check. The system confirms her identity and issues a verification confirmation through her GOV.UK account. She logs into the Companies House online portal, navigates to her director profile, and links her verification to the company. Her Personal Code is generated and stored.
When August 2026 arrives and the Confirmation Statement is due, Sarah's verified status is confirmed in the filing. The statement is accepted. Sarah has met the legal requirement with five months to spare.
Worked Example 2: A Director of Multiple Companies Using an ACSP
James is a director of three separate companies — a technology consultancy, a property holding company, and a family trading business. He does not have a smartphone compatible with the GOV.UK app and his only biometric document is an older passport that he believes may not have a functional NFC chip.
He contacts CoreAcc Accountants. We carry out the ACSP verification process with James, using his passport and a supporting document. We complete the verification and report the result to Companies House on his behalf. His Personal Code is issued and linked to all three companies simultaneously.
James has completed a single verification that covers all three companies. The cost is modest and the process takes less than an hour. He does not need to navigate the technical requirements of the GOV.UK app or repeat the process for each company individually.
Worked Example 3: A New Company Being Formed Today
Two co founders want to incorporate a new company today, 6 April 2026. Neither of them has previously verified their identity with Companies House.
If they attempt to file the incorporation documents without verifying, Companies House will reject the filing — both directors must be verified before the appointment is filed. They contact CoreAcc Accountants. We carry out the ACSP verification for both directors on the same day and include the verification references in the incorporation filing. The company is registered with both directors' verified status confirmed from the moment of incorporation.
From this point forward, any new company either of them joins as a director, or any filing they make in relation to a PSC registration, can use the same Personal Code they received today. The verification is done once and is permanent.
Frequently Asked Questions
Who must verify their identity under the new Companies House rules?
All directors of UK companies and LLPs, all Persons with Significant Control of UK entities, and all individuals filing documents at Companies House must verify their identity. The requirement applies to existing directors and PSCs as well as those newly appointed. It applies regardless of whether the company is trading or dormant. It applies to directors based overseas as well as those in the UK.
What is the deadline for existing directors?
Existing directors must complete identity verification by 18 November 2026. More precisely, they must verify before their company files its first Confirmation Statement after 18 November 2025. Since Confirmation Statement dates vary by company, some directors will need to verify before their statement falls due, which may be earlier than November 2026 for some companies. In all cases, verifying sooner is better than waiting for the deadline to approach.
What is the Personal Code?
The Personal Code is an 11 digit alphanumeric code issued by Companies House to each individual who has successfully verified their identity. It is permanent and does not expire. It follows the individual across all their company associations — a director of five companies has one Personal Code, not five. The code must be included in any filing that involves the individual's details. It is stored internally at Companies House but is not displayed publicly on the register.
What happens if I do not verify in time?
The consequences of not completing verification escalate over time. You will be unable to file Confirmation Statements and other documents at Companies House. Your name will be flagged as unverified on the public register, which is visible to banks, lenders, and anyone conducting due diligence on your company. Continuing to act as a director while unverified is a criminal offence. Persistent failure to comply can result in director disqualification for up to 15 years.
What is an Authorised Corporate Service Provider?
An Authorised Corporate Service Provider (ACSP) is an organisation registered with Companies House to carry out identity verification on behalf of individuals and report the result directly to the register. ACSPs must be regulated by an approved supervisory body. CoreAcc Accountants is a registered ACSP through our ACCA regulation, meaning we can verify your identity using acceptable identity documents and complete the process without you needing to use the GOV.UK One Login app. This is particularly useful for directors who do not have a compatible smartphone, who have documents without a biometric chip, or who prefer to have the process managed professionally.
Can I verify multiple company associations with one verification?
Yes. Identity verification is personal, not company specific. Once you have verified and received your Personal Code, that code is linked to every company you are associated with. You do not need to repeat the verification process for each company. If you are subsequently appointed as a director of a new company, you simply provide your existing Personal Code in the filing — no new verification is required.
What if I am based overseas?
The verification requirement applies regardless of where you are based. The GOV.UK One Login route has limitations for overseas directors — the app may not be available in all countries and may not function correctly with all non UK biometric documents. The ACSP route is the appropriate mechanism for overseas directors. CoreAcc Accountants provides remote verification services for directors based outside the UK, managing the process through acceptable identity documents and reporting the result to Companies House on your behalf.
Does verification cost anything?
The GOV.UK One Login self service route is free. Verification through an ACSP such as CoreAcc Accountants involves a professional fee, which reflects the time and regulatory responsibility involved in carrying out the verification to the required standard. For directors of multiple companies, the ACSP route provides a single process covering all associations — making the cost per company very modest.
What counts as an acceptable identity document for ACSP verification?
The list of acceptable identity documents for ACSP verification is broader than those compatible with the GOV.UK app. It includes biometric passports, biometric residence permits, national identity cards from EEA countries, and UK driving licences. It also includes certain documents without a biometric chip where supported by secondary evidence. CoreAcc Accountants will advise on the specific documents you should bring based on what you hold.
What CoreAcc Accountants Can Help You With
CoreAcc Accountants is a registered Authorised Corporate Service Provider through our ACCA regulation. We have been carrying out identity verifications for directors and PSCs since the regime went live in November 2025. We can verify you today.
For individual directors and PSCs, we carry out the full verification process and report the result directly to Companies House, generating your Personal Code without you needing to use the GOV.UK app.
For companies with multiple directors and PSCs, we can verify all individuals simultaneously in a coordinated process, ensuring that every person associated with the company is verified well ahead of the Confirmation Statement deadline.
For newly forming companies, we include identity verification as part of our company formation service, ensuring that both directors are verified before the incorporation filing is submitted.
For directors based overseas, we provide remote verification services using acceptable identity documents, managing the process entirely without requiring travel to the UK.
We also provide ongoing compliance monitoring — tracking the verification deadlines for all directors and PSCs associated with our clients' companies and alerting them when action is needed, so no deadline is missed.
Get in Touch
The deadline for existing directors is 18 November 2026. New directors must verify before their appointment is filed. Every week without verification is a week closer to the consequences of failure to comply.
Contact CoreAcc Accountants today to arrange identity verification. We can typically complete the ACSP verification process within a few working days of receiving your documents.
CoreAcc Accountants is an ACCA accredited firm of Chartered Certified Accountants and a registered Authorised Corporate Service Provider. This article was published on 6 April 2026 and reflects the identity verification requirements under the Economic Crime and Corporate Transparency Act 2023 in force at that date. It does not constitute legal advice. Always seek specific advice for your individual circumstances.
