ECCTA 2023: Mandatory identity verification for directors, LLP members and PSCs

Companies House has now confirmed that from 18 November 2025, it will become compulsory for all individuals who become directors, members of limited liability partnerships (LLPs), and persons with significant control (PSC) to verify their identity with Companies House.

In addition, there will be a 12-month transition period within which existing individual directors, members of LLPs and PSCs will need to verify their identity and provide their personal code (generated as part of the identity verification process) to Companies House. 

How the changes will affect directors and members of LLPs

Individuals that are currently directors and members of LLPs will have until the date of their company/LLP’s next annual confirmation statement, falling after 18 November 2025, to complete the identity verification (IDV) process. They will need to provide their personal code as part of the confirmation statement. If an individual is a director of more than one company, they will need to do this for each company.   

Any individual appointed as a director or LLP member on or after 18 November 2025 must complete identity verification before their appointment can be formally registered. Acting as a director or LLP member without having completed IDV after this date will constitute an offence. 

For existing individual PSCs, the period for completion of IDV varies depending on whether they are also a director of the same entity. When an individual is both a director and PSC of the same company, they must submit their personal code to Companies House on the following two separate occasions:

• As a director: Include their personal code in the company’s confirmation statement.
• As a PSC: Submit their personal code again through a new separate online service within 14 days following the confirmation statement date.

How the changes will affect PSCs

For existing individual PSCs who are not a director of the same entity, they must complete IDV and provide their personal code within the first 14 days of their birth month. For example, if their date of birth is 22 March, the 14-day period starts on 1 March 2026.

If an individual becomes a PSC after 18 November 2025, they will have to verify their identity and provide their personal code within 14 days from the date of their registration as a PSC at Companies House.

Future developments to Companies House

The IDV requirements will initially only apply to individuals. However, Companies House has confirmed that it will introduce IDV later for people who file at Companies House, limited partnerships, corporate directors of companies, corporate members of LLPs and officers of corporate PSCs.   

What do I need to do now?

• While the mandatory compliance date remains several months away, we recommend that all individual directors, LLP members, and PSCs complete IDV voluntarily as early as possible to avoid last-minute delays and ensure smooth future filings. Identity verification can be completed quickly and free of charge via the GOV.UK One Login service. For further details, please see our mini guide.
• Ensure that individuals keep a record of their personal codes.  
• Companies and LLPs should monitor their registered email address for further communications from Companies House regarding IDV.  
• From 18 November 2025, directors and PSCs should check the Companies House register to see the identity verification compliance dates for all their roles. 

Practical guide to the new identity verification requirements through GOV.UK

The quickest and cheapest method for an individual to verify their identity is through the GOV.UK One Login portal. This online service is free of charge and usually takes around 10 minutes to complete.

While the specific steps of the process will slightly differ depending on the ID documents the individual has and the devices (such as laptops, smartphones, or tablets) used to access the service, the following top tips apply universally:

Preparation 

Before starting the IDV process, the individual will need to have to hand one of the following types of photo ID:

• Biometric passport from any country.
• UK photo driving licence.
• UK biometric residence permit (BRP), UK biometric residence card (BRC) or UK Frontier Worker Permit (FWP).

They will also need details of their current address and the year they moved in. If they have lived at the address for less than 12 months they may be required to provide details of previous home addresses. Depending on what ID they have available, they may also be asked some security questions, such as details of their mobile phone contract, bank accounts or credit cards.

Accessing the service

Visit the verify your identity for Companies House page on the GOV.UK website and click on the “Verify your identity for Companies House” (green box) halfway down the page.

Creating/using a GOV.UK One login

The initial part of the process will guide the individual to either sign into their existing GOV.UK One Login account, or, if they do not have one, provide them with the option to create a new account using a valid email address.

This email address should not have been previously used by anyone else who has verified their ID. The email address must be the same as the email address for any existing Companies House account that they have in order to connect them.

Completing the ID verification process

The individual will be guided through a simple step-by-step process on screen. It will prompt the individual to confirm what ID they hold and devices (such as laptops, smartphones, or tablets) they have available. Depending on the information provided, the process varies slightly. Overall, the process is straightforward, typically involving a series of simple clicks.

As part of the process, it may direct the individual to download the GOV.UK ID Check app on a smart phone through which they will be asked to take a photo of their passport photo page, scan the biometric chip on their passport and scan their face with their selfie camera. Top tip: Ensure the selfie is taken in a well-lit area.

Unique identifiers number

Once the identity verification process is completed, it will confirm the individual’s unique identity verification number (also known as personal code) on screen.

Ensure that a note or screen shot of this number is kept safe (as the code is not being sent by email). Retaining this number is imperative, as it will be required to demonstrate that the individual’s identity has been successfully verified.

Alternatives

Although we expect most people will be able to verify their identity using the GOV.UK One Login portal, as an alternative, an individual can verify their identity through third party providers that are registered as an Authorised Corporate Service Provider (ACSP). This is likely to be the best solution where an individual does not have the ID documents listed above.

There are a number of ACSPs that are offering IDV services at a fee. Whilst Browne Jacobson will not be providing IDV, please contact us if you have any queries about using an ACSP to undertake IDV and we can share further information with you.

Recommended steps

• Identify individuals who will be required to have their identity verified and ascertain what ID they have available.
• Encourage those individuals who can use the GOV.UK One Login portal to do so before the requirements become mandatory.
• Identify those individuals who are unable to use the GOV.UK One Login portal and arrange for their ID verification through an Authorised Corporate Service Provider (ACSP).
• Ensure that individuals keep a record of their unique identifier number. 

Please see the downloadable summaries of our guide in English and French.