Trustee Identity Verification Form (Charitable Company Limited by Guarantee)

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 will be introduced for, amongst others, all new and existing directors (charity trustees) of charitable companies limited by guarantee (CCLBGs). 

Directors (trustees) who do not verify their identity will commit a criminal offence and/or incur a civil penalty. CCLBGs that have an unverified director (trustee) will also commit an offence. IDV is via biometric photographic ID. IDV is voluntary from 8 April 2025 but mandatory from 18 November 2025.

The ECCTA gives Companies House new and enhanced powers to help 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 directors (trustees), existing and new, as part of their own internal processes and to facilitate the IDV requirements of Companies House.

This template form should be completed and returned to the CCLBG by each new and existing director (trustee) together with a copy of their relevant biometric photographic ID attached. All information received should be 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.

We also have a letter explaining the identity verification regime and its timeline to directors (trustees). 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.

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Trustee Identity Verification Form (Charitable Company Limited by Guarantee) is part of Corporate. Just £38.50 + VAT provides unlimited downloads from Corporate for 1 year.