Companies House Identity Verification: A Complete Guide for Directors & PSCs

Quick Summary

From 18 November 2025, every director and Person With Significant Control (PSC) must verify their identity before they can act, be appointed, or file a confirmation statement. More than six million individuals will need to complete verification in the first year.

Verification can be completed using:

• GOV.UK One Login (online or through participating Post Office branches), or
• an Authorised Corporate Service Provider (ACSP) such as Smart Formations

Immediate Consequences of Not Verifying

A failure to verify has wide‑ranging and serious effects. The most important are:

Area Affected	What Happens
Companies House Filings	Incorporations, appointments, PSC updates, CS01s and accounts may be rejected.
Legal Penalties	Late filing penalties, non‑compliance fines, and potential criminal offences for acting unverified.
Public Record	A permanent public annotation appears on the Companies House register indicating unreliable or incomplete data.
Banking & Payments	Banks and payment providers may apply enhanced risk assessment, freeze accounts, delay payments, or refuse on boarding.
Credit Rating	Companies and individuals may experience downgraded credit scores due to flagged risk status.

These consequences create real‑world operational and financial risks for companies.

Why Companies House Identity Verification Rules Are Changing

For decades, Companies House accepted company documents without verifying who anyone actually was. This created opportunities for:

• impersonation and identity theft,
• fraudulent company appointments,
• opaque ownership structures,
• money‑laundering risks,
• misuse of UK companies overseas.

The Economic Crime and Corporate Transparency Act (ECCTA) reforms this. From 18 November 2025, identity verification becomes mandatory for anyone who manages, controls, or owns a UK company.

The goals of the reform:

• strengthen trust in the UK corporate register,
• prevent identity misuse and false filings,
• provide accurate beneficial‑ownership information,
• support banks and regulators with reliable data,
• reduce fraud and improve AML (Anti Money Laundering) compliance.

The reform affects 6–7 million people in its first year.

Who Must Verify

Identity verification applies to any individual involved in the legal management or control of a UK company.

Directors

All directors — new or existing — must verify. A person cannot legally act as a director without verification.

Persons With Significant Control (PSCs)

An individual is a PSC if they:

• own over 25% of shares,
• hold over 25% of voting rights,
• can appoint/remove a majority of directors,
• exercise significant influence or control,
• control a trust or partnership meeting these criteria.

Corporate PSCs (RLEs)

A Relevant Legal Entity (RLE) is a corporate entity that qualifies as a registrable Person with Significant Control (PSC) of a UK company and therefore must be recorded on the PSC register.

If a company is listed as a PSC, its managing officers must verify.

Directors Who Are Also PSCs

If someone is both a director and a PSC:

• they verify once,
• receive a single Personal Verification Code (PVC) — An 11-digit alpha numeric code e.g ABC12345678
• issued after successful verification; used to confirm verified status.
• but must declare the same PVC in two different locations: the CS01 and the PSC statement.

LLP Members and Future Groups

Companies House has indicated that many LLP members will also fall within the initial 18 November 2025 rollout. More roles — including corporate director managing officers and individuals who file documents on behalf of companies — will be added in later phases.

When Verification Must Be Completed

New Directors & PSCs

From 18 November 2025, a company cannot be incorporated unless all proposed officers verify first. Applications will not enter the queue until verification is complete.

Existing Directors

Must verify when filing their next confirmation statement (CS01) within the 12‑month transition year.

Existing PSCs

Have up to 12 months to complete digital identity verification (deadline: 18 November 2026).However , if any filing involving them is made earlier, they must be verified before that filing can be accepted.

Directors and PSCs will be able to log into the Companies House register to see their personal verification deadlines.

How Companies House Identity Verification Works

There are two main verification routes: GOV.UK One Login and ACSP verification

Before you start any route, ensure:

• your ID is valid and undamaged,
• the name at Companies House matches your legal ID exactly,
• you have good lighting for the face scan,
• you have stable access to email and MFA (Multi‑Factor Authentication) for One Login,
• your device can receive SMS or run an authenticator app.

Route 1 — GOV.UK One Login (Online or Via Post Office)

Most users can verify through One Login using:

• verified email,
• MFA setup (SMS or authenticator),
• biometric passport or ID scan,
• facial match.

Post Office in‑Branch Verification

For those unable to verify online — due to unsupported ID, technical issues, accessibility needs, or comfort level — GOV.UK One Login offers a Post Office in‑branch verification option.

This involves:

• starting verification online,
• receiving a secure reference or barcode,
• presenting ID at a participating Post Office branch,
• completing identity checks in person.

Companies House has not finalised national rollout details, but this route is expected to support those whose documents or devices are not well suited to online verification.

Route 2 — ACSP Verification

ACSPs (including Smart Formations) are authorised to conduct identity checks using regulated AML‑grade systems.

Benefits:

• supports non‑biometric and older passports,
• ideal for overseas directors and PSCs,
• avoids email/MFA and One Login setup risks,
• uses SmartSearch and SmartDoc for reliable document capture,
• includes human review when automated checks struggle,
• provides the same PVC as GOV.UK One Login.

PVCs do not expire unless Companies House requires re‑verification.

ACSP Record Retention (Five‑Year Rule)

As an ACSP, we must retain identity‑verification records for five years under the UK Money Laundering Regulations 2017 (MLR 2017). Documents are stored digitally, encrypted both at rest and in transit (AES‑256), and held in secure UK data centres compliant with ISO‑27001. After five years, records must be securely deleted unless ongoing monitoring or legal obligations require retention. This differs from the GOV.UK One Login system, which does not store your passport or ID image.

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Use our regulated ACSP Identity Verification Service to avoid One Login failures, email/MFA issues, and document‑capture problems. Start your verification securely with Smart Formations.

Why Verification Fails — Common Pitfalls

Even with clear instructions, many applicants encounter avoidable obstacles during verification. Early testing by government and ACSPs revealed that a significant proportion of GOV.UK One Login verification attempts fail due to practical issues rather than document problems. During early government and ACSP testing, 30–38% of GOV.UK One Login attempts failed due to:

• unsupported ID types,
• low camera resolution or poor lighting,
• mismatched Companies House records,
• overseas SMS/MFA failures,
• facial recognition mismatches.

Most failures can be prevented by preparing properly or using the Post Office or ACSP routes.

Email & MFA Risks — A Major Source of Avoidable Failure

Email and multi‑factor authentication may seem like minor administrative details, but they are among the most common reasons for failed verification. The GOV.UK One Login system links your digital identity to your email, meaning even small errors can cause long delays. One Login permanently links verification attempts to the email used.

Email Contamination

If a GOV.UK One Login attempt fails:

• that email is permanently associated with a failed identity record,
• switching emails does not reset the identity profile,
• identity recovery becomes mandatory.

Losing Access to Your Email

This can lock you out, triggering re‑authentication loops and delaying filings.

Account Corruption

Creating multiple accounts or switching emails mid‑process can corrupt identity records, leading to rejected filings or forced re‑verification.

ACSP Verification Avoids All Email Issues

ACSP verification does not depend on emails, login codes, or MFA.If a user cannot access their email, cannot receive verification codes, or has One Login issues, ACSP identity checks still work without interruption.

Banking, AML & Financial Consequences — The Real‑World Impact of failing to verify.

Beyond Companies House, the biggest risks of failing to verify are often financial. Banks, payment providers and FX platforms rely heavily on Companies House data, and unverified officers can trigger automated risk alerts within hours. Banks and financial institutions monitor Companies House in real time. When officers remain unverified, automated systems flag the company as higher risk.

Consequences include:

• delayed or frozen payments,
• onboarding rejection for new accounts,
• restricted merchant services (Stripe, PayPal, FX),
• enhanced due diligence (EDD),
• permanent account closure.

Banks also use the following third‑party AML databases that quickly republish Companies House annotations:

• Refinitiv World‑Check,
• ComplyAdvantage,
• Experian Business KYC,
• Dun & Bradstreet,
• LexisNexis Risk Solutions.

An unverified officer can therefore affect a company’s banking relationships within hours.

Legal Penalties & Regulatory Consequences of Not Verifying

In addition to banking and AML impacts, there are direct legal consequences for failing to verify. Many filings will be rejected, and continued non‑compliance becomes a criminal and civil matter.

Rejected Filings

Companies House will reject:

• incorporations,
• appointments,
• PSC updates,
• confirmation statements (CS01).
• Applications to dissolve a company (DS01)

Late Accounts

Late Filing Penalties Can Escalate Quickly. If verification delays cause missed deadlines, Companies House will treat accounts as late. Penalties start at £150 and can rise to £1,500, and are doubled if the company also filed late the previous year. Combined with rejected filings and public annotations, this can severely damage the company’s compliance record and reputation.

If the CS01 is rejected because required directors or PSCs have not verified, accounts may also be rejected or treated as late, triggering statutory penalties.

Statutory Late Filing Penalties for Private Companies

If verification delays cause accounts to be filed late, Companies House will apply penalties:

If the Annual Confirmation statement (CS01) is rejected because required directors or PSCs have not verified, accounts may also be rejected or treated as late, triggering statutory penalties.

Statutory Late Filing Penalties for Private Companies

If verification delays cause accounts to miss their deadline, Companies House will apply the following penalties:

Delay	Penalty
Up to 1 month	£150
1–3 months	£375
3–6 months	£750
Over 6 months	£1,500

If a company files late in two consecutive years, the penalty for the second year is automatically doubled.

If the CS01 is rejected, accounts may also be rejected or treated as late, triggering statutory penalties.

Criminal Offences

It is a criminal offence for an individual to act as a director while unverified. It is also an offence for a company to permit an unverified individual to act as a director. Failure to file the CS01 is also a criminal offence.

Civil Enforcement

Companies House may issue compliance notices and add public annotations. Companies House may also use existing enforcement powers, including restriction notices in appropriate circumstances, limiting the rights associated with shares or ownership until compliance is restored.

Strike‑Off

Persistent non‑compliance can result in compulsory strike‑off.

Extensions — When Companies House will allow extra time for verification

Extensions are rare and granted only where verification is genuinely impossible due to:

• lost or stolen ID,
• expired or damaged documents being replaced.

Companies House will require:

• evidence of replacement ID (renewal receipt, police reference),
• proof of an approaching statutory deadline,
• the expected date new ID will be available.

Identity Recovery — Why It Happens & How to Avoid It

If email or MFA issues prevent access to GOV.UK One Login, identity recovery becomes necessary. This process is slow because it involves:

• proving control of the original email,
• supplying extra evidence,
• manual review by the GOV.UK One Login security team,
• re-establishing MFA.

It can take days or weeks. ACSP verification avoids identity recovery entirely.

Responsibilities — You vs the Company

A smooth verification process depends on both sides fulfilling distinct roles.

Your Responsibilities (Directors & PSCs)

• Completing identity verification on time.
• Ensuring Companies House data matches legal ID.
• Maintaining email and MFA access.
• Providing valid, undamaged documents.
• Responding promptly to Companies House requests.

The Company’s Responsibilities

• Ensuring all officers verify before filings are submitted.
• Checking PVCs are issued and valid.
• Ensuring PSCs meet their birth‑month deadline.
• Requesting extensions only where legitimate.
• Not submitting filings that will inevitably fail.

Preparing to Verify (Practical Guidance)

Most failed attempts could be prevented by preparing properly.

Make sure your ID is valid and biometric where possible. Check that every character of your name matches your Companies House record. Test your camera and lighting. Ensure you have stable access to email and MFA — and if you have doubts, consider using the Post Office or an ACSP.

Quick Checklist

• Valid, undamaged ID (preferably biometric)
• Exact name match with Companies House
• Stable access to email and MFA
• Good lighting and working camera
• Reliable internet connection
• Consider Post Office or ACSP if unsure

Filings Submitted by Accountants, Solicitors or Agents

Many companies rely on accountants or solicitors to submit filings. Under the new regime:

• your agent can only submit if all directors and PSCs have verified;
• the agent does not verify on your behalf (unless they are an ACSP);
• the company remains legally responsible for ensuring all officers are verified.

Agents may also need to verify their own identity in later phases of the rollout. Companies House has indicated that individuals who file on behalf of companies will become a verification category in future updates.

Note on Public Visibility of Digital ID Verification Status

From 18 November 2025, Companies House will begin displaying verification-related information on the public register. However, it is important to understand exactly what is and is not visible.

What the public can see

• When a director or PSC has been verified, Companies House will show:
  • their name;
  • confirmation that they are a verified individual;
  • if verified by an ACSP: the name of the ACSP and the AML-supervisory bodies involved;
  • the date the identity check was completed.

What the public cannot see

• There is no public flag, marker, or label showing that a director or PSC is unverified.
• There is no public list of individuals who have not completed digital ID verification.
• An absence of verification data cannot reliably be interpreted as non-verification—e.g., transitional deadlines may not have passed yet.

Important implications

• Although non-verification is not publicly highlighted, it will still prevent the company from:
  • filing its Confirmation Statement;
  • filing its annual accounts;
  • filing any other statutory documents;
  • appointing, removing, or updating officers/PSCs.
• This can quickly escalate to:
  • warning notices,
  • late-filing penalties,
  • a potential compulsory strike-off,
  • and in some circumstances a public annotation if Companies House uses its s1092A or s1002A powers.

Why directors should take this seriously

Even though the register won’t publicly “name and shame” unverified individuals, the practical consequences are severe and the company’s compliance history becomes visible to lenders, suppliers, due-diligence teams, and credit-rating agencies.

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Conclusion: Navigating the New Verification Era

The shift to mandatory identity verification marks one of the most significant changes to UK company administration in decades. While the process is designed to strengthen the integrity of the Companies House register, it also introduces new responsibilities—and real‑world consequences—for directors and PSCs.

The most immediate risks lie not only in rejected filings but in the wider financial ecosystem. Banks, payment processors and credit platforms actively monitor verification status, meaning that unresolved verification can quickly translate into frozen banking facilities, onboarding refusals, and damage to a company’s financial reputation.

For those uneasy about technology, the availability of the Post Office route within the GOV.UK One Login system offers a familiar, face‑to‑face alternative. And for overseas individuals or anyone dealing with older or non‑biometric ID, a trusted ACSP provides a secure and reliable route that avoids the email and MFA pitfalls of One Login.

The message is clear: verify early, prepare properly, and choose the verification route that gives you the highest chance of success. By taking proactive steps now, companies and individuals can avoid penalties, prevent filing delays, and protect their banking and compliance standing in the year ahead.

Glossary of Key Terms

ACSP (Authorised Corporate Service Provider) — A regulated firm authorised to verify identities and conduct AML checks.

Annotation — A public note on the Companies House register indicating unverified or unreliable information.

Confirmation Statement (CS01) — The annual filing confirming company details and used to declare director and PSC verification.

Director — An individual legally responsible for managing a company; must verify identity before acting.

GOV.UK One Login — The government’s digital identity platform for self‑service verification.

Identity Recovery — The process required when access to One Login is lost or a verification attempt becomes contaminated.

MFA (Multi‑Factor Authentication) — A second verification step (SMS or authenticator app).

Personal Verification Code (PVC) — An 11‑digit code issued after successful verification; used to confirm verified status.

PSC (Person With Significant Control) — An individual with significant ownership or control of a company.

RLE (Relevant Legal Entity) — A corporate PSC; its managing officers must verify.

Strike‑Off — Removal of a company from the Companies House register.

End‑to‑End Encryption (E2EE) — A method of securing data so it is encrypted on your device and decrypted only by the intended recipient.

AML Retention (Five‑Year Rule) — ACSPs must retain identity‑verification records for five years under the Money Laundering Regulations 2017. Records are stored in encrypted digital form and securely deleted after the retention period unless ongoing monitoring applies.

Before stepping into the final section, it is worth noting that all these reforms work together to reshape how individuals interact with Companies House, and how the wider financial system interprets company data.