Digital Identity Verification & KYC for UK Company Formations

Companies House requires digital identity verification for all directors and PSCs – Smart Formations provides this service as an Authorised Corporate Service Provider.

Quick Read Summary

From 18 November 2025, all company formations in the UK will require digital identity verification for directors and PSCs before submission to Companies House. Smart Formations, as an Authorised Corporate Service Provider (ACSP), offers secure, GDPR-compliant verification services for both UK and non-UK applicants. Verification involves matching an official photo ID with a live facial image and issuing a permanent 11-digit Personal Verification Code (PVC). This requirement arises under the Economic Crime and Corporate Transparency Act 2023 and the updated Companies Act 2006 provisions on digital identity validation.

BEFORE A COMPANY CAN BE FORMED – ALL DIRECTORS AND PSCs MUST BE DIGITALLY VERIFIED

Starting 18 November 2025, Companies House will not register any new company unless every proposed director and Person with Significant Control (PSC) has completed digital identity verification.

Digital verification involves matching your photo ID (such as a passport or driving licence) with a live facial image taken from your smartphone. Once verified, you will receive an 11-digit Companies House Personal Verification Code (PVC), which serves as permanent proof that you are authorised to act as a director or PSC. You can begin your company formation order with Smart Formations even if you have not yet acquired your Verification Code.

During the ordering process, you may:

• Complete verification through Smart Formations (as an Authorised Corporate Service Provider – ACSP), or
• Verify yourself via GOV.UK One Login.

Once all directors and PSCs have entered their 11-digit codes, the application automatically proceeds to Companies House, pending standard Anti-Money Laundering (AML) and Know Your Customer (KYC) checks.

Alternative Routes to Digital Identity Verification

There are two ways to complete the Companies House verification requirement:

Route 1 – GOV.UK One Login

This option suits most UK-based applicants with accepted UK ID. It takes about 5–10 minutes and provides your code instantly, which can be reused for future appointments.

Route 2 – Smart Formations (ACSP)

This option is designed for non-UK residents or those whose ID is not accepted by GOV.UK. Upload a biometric or machine-readable passport and a live facial image. Verification is completed within 24–48 hours. Smart Formations uses SmartSearch for digital checks, aligning with FATF 2024 guidance and HMRC TCSP supervision standards.

Accepted ID Documents

To use GOV.UK One Login, you must present a UK-issued photo ID. The system matches your ID with a live facial image from your smartphone or webcam.

Accepted IDs:

• Current UK passport (biometric)
• UK photocard driving license (full or provisional)
• Home Office Biometric Residence Permit (BRP)
• UK biometric Residence Card (BRC)
• UK Frontier Worker Permit (FWP)

Not Accepted:

• Non-UK passports or national ID cards
• Paper driving licenses
• Birth or naturalisation certificates, utility bills, or bank statements

If you do not possess an accepted UK ID or if GOV.UK One Login cannot read it, use the Smart Formations ACSP digital ID service. Non-UK residents must meet enhanced due diligence standards under Regulation 33 of the Money Laundering Regulations 2017.

GOV.UK One Login and Companies House – How They Connect

The GOV.UK One Login site and Companies House are separate entities. GOV.UK One Login (managed by the Government Digital Service) verifies identity and issues the 11-digit code, while Companies House accepts company filings only after all directors and PSCs have completed verification.

Smart Formations integrates both steps within one secure formation workflow, ensuring a compliant and seamless process that meets the obligations of the Economic Crime and Corporate Transparency Act 2023 and the Money Laundering Regulations 2017.

Email Address Rules

Your GOV.UK One Login email becomes tied to your verified record.

• Successful verification permanently associates that email with your PVC.
• If verification fails, you cannot reuse that email to attempt again.
• You may retry using a different email or improved documentation.

This rule only applies to GOV.UK One Login and not to Smart Formations accounts.

Secure Uploads, Proof of Address & Data Protection

Smart Formations offers two encrypted methods for secure document submission:

• Upload via the Tresorit-powered encrypted portal (ISO 27001-certified).
• Upload via a SmartSearch link to our UK-accredited e-ID provider.

All uploads are encrypted during transfer (TLS 1.3) and storage (AES-256) and stored only in UK data centres. Files are deleted after completion or after statutory retention periods.

Proof of Address:

If requested, acceptable documents include:

• For UK residents: A recent bank statement, utility bill, HMRC/DWP letter, or driving licence (current address).
• For Non-UK residents: A recent utility bill or government-issued correspondence in English (or a certified translation).

Smart Formations complies with UK GDPR, the Data Protection Act 2018, and OPBAS requirements for TCSPs. Data retention aligns with Regulation 40 of the Money Laundering Regulations 2017.

Our AML & KYC Legal Duties

Even with digital verification, Smart Formations must perform AML and KYC checks in accordance with the Money Laundering Regulations 2017. We are supervised by HMRC as a Trust and Company Service Provider (TCSP) and follow guidance from HM Treasury, OPBAS, and FATF 2024.

We must:

• Identify and verify clients (Regulation 28(2)).
• Verify beneficial owners and PSCs (Regulation 28(3)).
• Obtain information on business purpose (Regulation 28(5)).
• Conduct ongoing monitoring (Regulation 40).
• Apply enhanced measures when higher risk arises (Regulation 33).

Our procedures reflect obligations under the Companies Act 2006, the Economic Crime and Corporate Transparency Act 2023, and the FATF Recommendations 10 and 24 concerning beneficial ownership transparency.

Continuous Monitoring & High-Risk Cases

Smart Formations uses SmartSearch for automatic client monitoring. If an individual or entity becomes associated with sanctions, PEP status, or adverse media, our system alerts us immediately.

We also respond to:

• Law enforcement requests (NCA, HMRC, SFO)
• Regulator or solicitor inquiries about suspected misuse
• Adverse media or credible complaints about company activity

When required by law, Smart Formations will suspend services and file a Suspicious Activity Report (SAR) under Regulation 28(11), ensuring compliance with UK AML standards.

If You Do Not Pass Verification

If verification fails, Smart Formations will request alternative ID and address proof. If still unsuccessful, your formation cannot proceed.

In accordance with Companies House policy, no submission may be made without valid PVCs for each director and PSC. Refunds exclude SmartSearch or verification fees once processing begins.

Glossary of Key Terms

ACSP (Authorised Corporate Service Provider): A Companies House–authorised intermediary (e.g., Smart Formations) permitted to verify identities for incorporations and filings.

AML (Anti‑Money Laundering): The legal and operational framework that prevents the movement of criminal property. UK obligations primarily arise under the Money Laundering Regulations 2017.

Beneficial Owner: The natural person(s) who ultimately owns or controls a customer or on whose behalf a transaction is conducted; for companies this often aligns with PSC rules but can be broader.

CIP / CDD (Customer Identification / Customer Due Diligence): The processes required under MLR 2017 Reg. 28 to identify and verify customers before providing regulated services.

Companies House Personal Verification Code (PVC): The 11‑digit unique identifier issued after digital identity verification; required to act as a director/PSC and to deliver filings.

ECCTA 2023: Economic Crime and Corporate Transparency Act 2023 – UK legislation reforming Companies House and introducing mandatory identity verification for directors/PSCs and those delivering filings.

EDD (Enhanced Due Diligence): Additional checks applied in higher‑risk situations under MLR 2017 Reg. 33 (e.g., non‑UK residency, complex structures, adverse media, PEP factors).

GOV.UK One Login: The Government Digital Service (GDS) identity service used to complete digital verification and obtain a PVC.

KYC (Know Your Customer): The process of identifying the client, understanding ownership/control and purpose, and assessing ongoing risk.

OPBAS: Office for Professional Body Anti‑Money Laundering Supervision – oversees how professional bodies supervise AML compliance.

PEP (Politically Exposed Person): An individual entrusted with prominent public functions (and their close associates); triggers EDD under MLRs.

PSC (Person with Significant Control): An individual who (typically) holds >25% shares or voting rights, has significant influence or control, or the right to appoint/remove a majority of the board.

SmartSearch: UK‑accredited electronic ID and AML screening provider used by Smart Formations for verification and ongoing monitoring.

TCSP (Trust and Company Service Provider): A business carrying out company formation/management services; Smart Formations is supervised by HMRC as a TCSP.

Statutory References & Citations

Primary legislation & regulations

• Economic Crime and Corporate Transparency Act 2023 – identity verification framework for directors, PSCs and those delivering filings (Part 1: Companies; commencement regulations as in force).
• Companies Act 2006 (as amended) – company incorporation and filing duties (including changes introduced by ECCTA 2023).
• Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 (MLR 2017, SI 2017/692) – esp. Reg. 28 (CDD), Reg. 33 (EDD), Reg. 40 (record‑keeping), Reg. 35 (PEPs).
• Data Protection Act 2018 and UK GDPR – lawful processing, security, and retention of personal data.

Official guidance & supervisory materials

• HM Treasury / OPBAS – AML supervision expectations for TCSPs.
• FATF Recommendations (updated 2024) – esp. Rec. 10 (CDD) and Rec. 24 (beneficial ownership transparency).
• GDS (GOV.UK One Login) guidance – process for digital identity verification and PVC issuance.

Notes on application

• PVC prerequisite: Companies House will not accept incorporation where any director/PSC lacks a valid PVC.
• EDD triggers: Non‑UK residency, complex control structures, PEP links, sanctions, or adverse media may require additional documentation and verification steps.

Contact Our Compliance Team

Email: [email protected]

Tel:02039664860

Address: Smart Formations, London WC1N 3AX