If your practice hasn’t yet built identity verification into your Companies House workflow, now is the time. The transition period began on 18 November 2025 and runs for 12 months, with directors and PSCs required to meet identity verification deadlines based on their individual circumstances. For firms managing filings across dozens or hundreds of client companies, this is not a one-off task but a significant compliance project.

What actually changed?

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) introduced mandatory identity verification for company directors, People with Significant Control (PSCs), and LLP members. The rollout has happened in stages:

• 18 March 2025: Third-party providers could begin registering as Authorised Corporate Service Providers (ACSPs).
• 8 April 2025: Identity verification became available voluntarily.
• 18 November 2025: A 12-month transition period began for existing directors and PSCs, with the exact identity verification deadline depending on the individual’s role and circumstances.
• 18 November 2025 – 18 November 2026: Existing directors, LLP members and PSCs (appointed before 18 November 2025) sit in a 12-month transition period.

For anyone already in post before 18 November 2025, the headline “November 2026” deadline is really a backstop. The practical deadline is earlier for most companies, because it’s tied to the confirmation statement.

The Deadline that Actually Matters: Your Confirmation Statement

Existing directors and LLP members must verify their identity by the time their company’s next confirmation statement is filed on or after 18 November 2025. When filing the relevant confirmation statement, the company must provide the required Companies House personal codes and confirm that its directors have completed identity verification. Companies House will not accept the confirmation statement until the relevant identity verification requirements have been met.

PSCs work slightly differently: those who are also directors must verify within 14 days of the confirmation statement date; PSCs who aren’t directors have a 14-day window starting on the first day of their birth month as recorded on the register.

In practice, this means a client with a confirmation statement due in February 2026 has a far tighter effective deadline than one whose statement isn’t due until October 2026,  even though both technically sit within the same “12-month transition period.” This is the detail that trips firms up when they plan around the headline November date alone.

A Separate Change: ACSP Registration and Future Filing Requirements

An Authorised Corporate Service Provider (ACSP) is a business or individual that is registered with Companies House and authorised to carry out certain activities for clients, including identity verification. To register as an ACSP, the business or individual must meet the relevant eligibility requirements, including being supervised for anti-money laundering purposes.

Accountancy firms should also keep separate Companies House filing reforms on their radar. Companies House has announced changes to the way third parties file information on behalf of clients, but these wider authorised-agent filing requirements are expected to apply no earlier than November 2026.

This is separate from the identity verification transition. Firms that want to verify clients’ identities for Companies House purposes on their behalf need to use the appropriate ACSP route and meet the relevant requirements.

This type of statutory administration, including confirmation statements and company secretarial processes, can form part of structured company secretarial support. Firms managing a large client portfolio should make sure responsibility for these processes is clearly assigned internally.

Verification routes for directors and PSCs

There are two practical paths:

• GOV.UK One Login (direct route): Individuals can verify directly using an eligible identity document and the available GOV. UK verification process. The documents and steps available can depend on the individual’s circumstances.

• Verification via an ACSP: An individual may use an Authorised Corporate Service Provider that is registered with Companies House to carry out identity verification on their behalf. 

What Happens if a Client Misses it?

The consequences escalate:

• The confirmation statement cannot be filed while any director remains unverified.
• An unfiled confirmation statement puts the company at risk of being struck off the register.
• Companies House will not accept a confirmation statement until the relevant identity verification requirements have been met.

What Firms Should Be Doing Now?

For a practice managing a large client bank, the sensible order of operations is:

• Audit your client list against upcoming confirmation statement dates and identify directors and PSCs who still need to complete identity verification. Prioritise clients with the earliest applicable deadlines.

• Confirm your own ACSP registration status. This is a firm-level obligation, separate from client verification, and it’s already live.

• Decide your verification model: will clients self-serve via GOV.UK One Login, or will your firm verify them as an ACSP? Larger client banks with overseas directors often benefit from a hybrid approach.

• Build verification into onboarding for any new client going forward, since new appointments already require it.

The volume problem is the real challenge here: verifying two or three clients is straightforward; verifying several hundred against a rolling set of confirmation statement dates, chasing non-responsive directors, and keeping records audit-ready is an entirely different operational task. This is exactly the kind of structured, deadline-driven admin that firms are increasingly building into their outsourced back-office workflows rather than absorbing into fee-earner time during an already busy compliance calendar.

Frequently Asked Questions

Is Companies House identity verification the same as AML due diligence? 

No. Companies House identity verification and AML customer due diligence are separate compliance processes. Companies House identity verification is designed to confirm a person’s identity for Companies House purposes, while AML customer due diligence forms part of wider risk-based compliance obligations. Completing one does not automatically satisfy the other.

Do overseas directors need to verify too? 

Yes. Identity verification can apply to directors regardless of their nationality or where they live. However, overseas companies with a UK establishment may be subject to separate Companies House procedures and deadlines, so accountants should check the requirements that apply to the specific entity.

Can a director file a confirmation statement early to get verification out of the way? Yes. Confirmation statements can be filed early within the review period, so a firm that wants to close out verification ahead of a client’s normal due date can bring the filing forward rather than waiting.

What happens to a company if verification is missed entirely? 

Companies House may not accept the relevant filing until the applicable identity verification requirements have been met. If a company continues to miss its statutory filing obligations, it may face enforcement action and, ultimately, the risk of being struck off the register.