Briefing note: New Identity Verification Requirements

Overview of the Identity Verification Requirement

The ECCTA requires identity verification for key individuals associated with UK companies to enhance corporate transparency and combat economic crime.

Who must verify their identity?

• All company directors, both new appointees and those already in office.
• PSCs: individuals holding more than 25% of shares or voting rights or exercising significant influence or control over a company.
• In due course, mandatory identity verification will also be introduced for positions including managing officers and persons in charge of filing at Companies House (such as a company secretaries).

How will the process work?

• Individuals must submit proof of identity to Companies House directly or via an authorised agent of Companies House, such as a registered firm of solicitors.
• Following successful identity verification, individuals will be provided with a ‘personal code’ to serve as their unique identifier going forward. This personal code can then be used at any point where identity verification is required for Companies House (e.g. when filing a confirmation statement).

What are the timelines?

• From 18 November 2025, the proposed directors / PSCs for any new company, or any new directors being appointed to an existing company, will require a verified personal code.
• For existing directors at existing companies, those directors will require a personal code in time for filing of their company’s next confirmation statement from 18 November 2025 onwards. Where an existing director is also a PSC, they will be required additionally to provide identity confirmation within 14 days of the confirmation statement (this time in their capacity as a PSC).
• For existing PSCs who are not directors, they must provide identity verification within the first 14 days of their birth month (e.g. non-director PSCs born in March must provide identity confirmation by 14 March 2026).

What happens if you fail to comply?

• Non-compliance could lead to serious consequences, such as directors, PSCs and/or the company being fined, and/or directors or PSCs being prohibited from serving in their roles.
• Non-compliance could also lead to indirect penalties e.g. failing to have the proper identity verification in place could lead to a delayed filing, which could in turn lead to a fine for missing a deadline.
• A company’s registration may also be impacted if its directors or PSCs have not completed verification.

Practical Steps to Ensure Compliance

To ensure compliance with these requirements, all UK-registered companies should:

• Identify individuals serving as directors, PSCs and other relevant positions who may fall under the scope of the verification requirement.
• Prepare for the identity verification process, ensuring the necessary documentation is available (e.g., passports, driving licences).
• For existing companies, analyse company filing deadlines to determine when director and PSC identity verification will be required (e.g. by reference to the confirmation statement deadline). Ensure that all directors / PSCs have verified their identities ahead of the relevant deadlines. It is open to individuals to verify their identities on a voluntary basis (i.e. before the mandatory deadlines take hold), which is an advisable strategy to avoid any last-minute rush.
• For prospective companies / prospective appointments, ensure that identification verification is in place ahead of time to avoid any delays to the appointments.
• Track announcements from Companies House regarding the relevant deadlines that are yet to be confirmed (such as the implementation of mandatory identify verification for company secretaries).

How Onside Law Can Assist

Onside Law can provide tailored guidance to assist you with the above and help you meet these new requirements, including:

• Assessing which of your directors, PSCs and other personnel are subject to the new rules.
• Determining the relevant deadlines applicable to each relevant individual.
• Monitoring compliance deadlines to ensure that your organisation avoids penalties.
• Supporting the documentation and submission process for identity verification.

These changes represent a critical shift in the UK’s approach to corporate governance and transparency. Failure to comply with the ECCTA provisions could result in significant operational, legal, and reputational risks for companies and individuals alike.

Companies or individuals unsure of their obligations under this new legislation should seek legal advice promptly.

For further information or assistance, please contact us at info@onsidelaw.co.uk.