UK counts down to identity checks for all directors and persons with significant control from November
Published on 29th August 2025
Seven questions answered to help prepare as the significant change approaches
Mandatory identity verification checks, which are set to start from 18 November this year, will apply to millions of individuals involved in corporate entities in the UK.
Under measures introduced by the Economic Crime and Corporate Transparency Act 2003, the UK's corporate register is rolling out the new identity verification requirement as part of significant reforms that aim for company ownership to be more transparent.
Who will need to have their identity verified?
The roll-out of identity verification is happening in stages starting with individual directors of UK companies, members of UK limited liability partnerships (LLPs) and persons with significant control (PSCs).
Who will (and won't) eventually need to be verified (in each case, the nationality or residence of the individual is irrelevant)?
| Description of person | Verified? |
| Individual directors of a UK company | Y |
| Individuals who are registered as a person with significant control (PSC) | Y |
| Where a PSC is a corporate entity (known as a relevant legal entity (RLE)), an individual who is a relevant officer of that RLE | Y |
| Individual directors of a non-UK company operating a UK branch which is registered as a UK establishment | Y |
| Where a director is a corporate entity, one or more individual officers of that entity | Y |
| Shareholders/members/stockholders of a UK company or non-UK company | N |
| Individual members of a UK LLP | Y |
| Where a member of a UK LLP is a corporate entity, one or more individual officers of that entity. | Y |
| Individual general partners of a UK limited partnership (LP) | N |
| Where a general partner of a UK LP is a corporate entity, an individual who is a managing officer of that corporate general partner | Y |
| Limited partners of a UK limited partnership (LP) | N |
| Individuals filing documents at the UK company registry known as Companies House, other than when the filings are made via an authorised corporate service provider (ACSP). | Y |
It is not clear yet how corporate directors will be verified. The government has previously announced that in the future only UK corporate entities with legal personality (such as other UK companies or UK LLPs) will be able to be appointed as corporate directors. The directors of these corporate directors will need to be natural persons whose identities have been verified.
Likewise, it is also unclear how corporate members of LLPs will be verified. The government has previously stated that, where a member of an LLP is a corporate entity, one of its individual directors (or equivalents) will also be required to verify their identity.
There appears to be a difference of treatment between individual general partners of UK LPs and corporate general partners of UK LPs in the primary legislation. It remains to be seen whether this difference will be closed via secondary legislation. In practice, individual general partners of UK LPs are rare due to the unlimited liability to which general partners are subject.
What is the deadline for verification?
The government recently confirmed that the mandatory verification will be phased in from 18 November for all individual directors of UK companies and all individuals who are registered as a PSC. Although not mentioned in the government's press release, it is understood that individual members of UK LLPs will also be included in this first wave.
The implementation date for all other categories, including individuals who are officers of an RLE, is not yet known.
Individuals and corporate entities will need to carefully identify the applicable deadlines, as unfortunately there is not a "one size fits all" approach. Individuals will only need to be verified once, but will need to notify Companies House of their personal code in respect of each separate appointment or role. This means that an individual may have multiple applicable notification deadlines for different roles at different companies. Individuals will need to identify their earliest deadline and ensure that they have been verified by that date. They will then potentially have to notify Companies House of their verification multiple times in respect of each different role or appointment.
From 18 November, existing directors and PSCs will be able to check the Companies House register to see identity verification notification due dates for all their roles. Companies House has taken this measure to help directors and PSCs with compliance with the deadlines.
| Description of person | Deadline |
| Individual who is appointed as a director of a UK company or member of a UK LLP on or after 18 November. | In advance of the appointment. If the appointment is being made as part of the incorporation of a new company or LLP, verification will need to have happened in advance of incorporation. The incorporation will not be able to proceed without codes for all relevant individuals. |
| Individual who is registered as a PSC on or after 18 November. | Within 14 days of being registered as a PSC. |
| Individual who is a director of a UK company or member of a UK LLP on 18 November, but not a PSC of that company or LLP. | Before the first confirmation statement of the company or LLP on or after 18 November. It is understood that only appointments that are current at the time of the confirmation statement will need to be verified; directors or members whose appointment was terminated before the confirmation statement date will not need to be verified – although this detail has not been confirmed. |
| Individual who is a director of a UK company or existing member of a UK LLP on 18 November and is also a PSC of the same company or LLP. | As a director or member, before the first confirmation statement of the company or LLP on or after 18 November. As a PSC, within 14 days of the first confirmation statement of the company or LLP on or after 18 November. Two notifications will need to be made: once as a director or member as part of the confirmation statement process and once as a PSC via a separate notification process. Again, it is understood that only appointments current at the time of the confirmation statement will need to be verified – but this detail has not been confirmed. |
| Individual who is a PSC on 18 November but not a director of the same company or member of the same LLP. | Within the first 14 days of the person's birth month. For example, if the person's birthday is 22 January, their 14-day period will begin on 1 January 2026 and their deadline will be 14 January 2026. It appears from the government press release that verification notifications will need to be made in the 14-day window; however, it is anticipated that, in practice, earlier notifications will be permitted. It is not yet known what will happen if an individual ceases to be a PSC between 18 November 2025 and the applicable deadline. |
How does a person become verified?
Individuals are already able to voluntarily verify their identity and individuals will likely want to take steps to verify their identity now – and well in advance of the deadlines.
Verification can be carried out via the official GOV.UK One Login. This is a free of charge service which can be accessed by an app, on a browser or, if required, in person at a UK post office. The government has published guidance on how to use this free verification service.
Alternatively, verification can be carried out for a fee by an authorised corporate service provider (ACSP) that provides a verification service. Some circumstances where an ACSP may be helpful include where:
- An individual does not have a biometric passport.
- An individual's passport is in a different name to their professional name used in their corporate appointments.
- An individual would benefit from a concierge service, rather than self-serve.
How does a person tell Companies House that they have been verified?
Once verified, the individual will be sent a personal code. This code should be kept secure but accessible. It will need to be provided to Companies House for each role by the applicable deadline referred to above.
For directors of UK companies and members of UK LLPs, the personal code will need to be provided as part of any new appointment, incorporation or confirmation statement process, as applicable.
For PSCs, the personal code will need to be provided via a separate notification process.
None of the notification processes are currently live.
Many individuals may have slightly differing records for different appointments (for example, someone may show their middle names for one director appointment, but only their first and last name for another appointment). It is not yet known whether those differences will need to be reconciled in advance or whether Companies House will accept personal codes where there is a slight variation between the verified information and the information on its record.
What will be shown on the public register about verification?
An individual's personal code will never appear on the public register, nor will any information or documentation provided as part of the verification process.
From 18 November, existing directors and PSCs will be able to check the Companies House register to see identity verification due dates for all their roles.
Once verified, it is understood that an individual will have a "verified" marker attached to their appointment. Individuals who have missed their deadline will consequently be marked as "unverified".
What are the consequences if an individual misses their verification notification deadline?
An individual who has not been verified is prohibited from acting as a director. Government guidance is that a director should not take any actions on behalf of the company in their capacity as a director until they have been verified.
Although the legislation makes clear that a director's appointment and the actions they have taken are still valid, if a person continues to act as a director without verification, they and the company are committing a criminal offence – albeit that prosecutions for non-compliance are likely to be rare.
There is another more practical consequence for existing directors or members of LLPs. It is likely that it will not be possible for a company or LLP to file its confirmation statement without those individuals being verified and so the company may be liable for late filing penalties.
Will verification need to be refreshed?
An individual's verification will not expire, and reverification is not expected to be required routinely, or as a response to specific events. Individuals are likely to only need to reverify if requested to do so by Companies House.
Individuals may be asked to reverify if Companies House has reasonable cause to believe that any information or evidence provided to them as part of the verification process is misleading, false or deceptive in a material particular. This may arise in practice, for example, when Companies House compares information it holds against the information held by credit reference agencies, and the information no longer matches (for example, because the individual has changed their name after marriage or divorce).
To find out more or discuss particular circumstances, please contact your usual Osborne Clarke contact or one of our experts. Additionally, we are able to introduce our clients to a trusted ACSP for identity verification, should this be required.
