Charitable Company Limited By Guarantee Letter to Trustee Re Confirmation of Identity Verification 
The introduction of identity verification is one of the key changes to UK company law under the Economic Crime and Corporate Transparency Act 2023 (ECCTA).
New identity verification (IDV) requirements have been introduced for all new and existing charity trustees (directors). Trustees/directors who do not verify their identity will commit a criminal offence and/or incur a civil penalty. Charitable companies limited by guarantee (CCLBGs) that have an unverified trustee/director will also commit an offence. IDV is via biometric photographic ID.
IDV is voluntary from 8 April 2025 but becomes mandatory from 18 November 2025.
The ECCTA gives Companies House new and enhanced powers to disrupt economic crime and the IDV regime is a key component of this.
Considering this significant change, CCLBGs should get into the habit of verifying the identity of each of their trustees/directors, existing and new, as part of their own internal processes and to facilitate the IDV requirements of Companies House.
This template letter should be sent by a CCLBG to a trustee/director requesting that they prove their identity in accordance with the Registrars' (Identity Verification by the Registrar) Rules 2025. This will also help highlight any discrepancies in filings at Companies House, for example a change of name or use of a maiden name and flag whether an identity document needs renewing ahead of the compulsory IDV process. This will all help lessen the likelihood of a missed deadline or a potential fine once the IDV regime becomes compulsory on 18 November 2025.
All information received should be collected, held and processed in compliance with UK General Data Protection Regulation (UK GDPR). Note that the CCLBG will need to identify a lawful basis for processing personal data and ensure that this can be justified. Complying with a legal obligation will fulfill this. More information is available on the ICO’s website here.
The Identity Verification Form should be included with this letter and returned by the trustee/director with the relevant ID.
We also have a letter explaining the identity verification regime and its timeline to trustee/directors. This can be accessed here.
Companies House guidance in relation to the IDV process is available here.
The document is in open format. Fields should be completed and wording in square brackets is optional and can be deleted or retained according to requirements.
Once you have subscribed to the Corporate Document Folder click on the “Download Document” button below. You will be asked what you want to do with the file. It is recommended that you save the document to a location of your choice prior to viewing.
Charitable Company Limited By Guarantee Letter to Trustee Re Confirmation of Identity Verification is part of Corporate. Just £38.50 + VAT provides unlimited downloads from Corporate for 1 year.