New Identity Requirement at Companies House - Voluntary Registration for Directors & PSCs Begins

One of the key reforms to company law being brought in by the Economic Crime & Corporate Transparency Act 2023 (ECCTA) is the requirement for directors and persons of significant control (PSCs) as well as those delivering documents to Companies House, to have their identity verified (IDV). Anyone who is already a director and anyone becoming a director for the first time will need to go through an identity check. Once fully in force, a director will not be permitted to act, and companies must ensure that a person does not act, as a director, unless their identity has been verified. Individuals who are PSCs, or relevant officers of a company registered as a PSC, will also need to undergo IDV checks. IDV will impact every UK registered company.

The ECCTA is a landmark legislation designed to give Companies House new and enhanced powers to help disrupt economic crime. 

Since 8th April 2025, directors and PSCs have been able to voluntarily verify their identity ahead of the compulsory IDV process that is expected to begin in Autumn 2025. Verifying early means that if complications arise there is less likelihood of missed deadlines and potential fines for non-compliance as well as being ahead of the vast bulk of people that will be undergoing IDV once the regime becomes compulsory. This is estimated at over 7 million people. In addition, as IDV is envisaged to happen as part of the annual confirmation statement filing, once mandatory IDV comes into force, existing directors could have as much as 12 months to complete their IDV but it could also occur shortly after the new requirements take effect.

Individuals can either verify their identity directly with Companies House or through an Authorised Corporate Service Provider (ACSP), such as a lawyer or an accountant. Applications to become an ACSP opened with Companies House on 18th March 2025. It is expected that IDV will be a quick, easy and free process for most using the Government’s One Login Service. For those companies with groups, overseas directors or relevant legal entities, IDV may be more complicated and may have to be undertaken through an ACSP.

It is now essential that companies make sure all their directors and PSCs know about IDV requirements.

Considering this timetable, our templates that relate to this process and particularly the letters informing directors and PSCs about the requirements have been updated, including: 

• Confirmation of identity letter, 
• Identity verification form, 
• Letter to directors regarding ID verification,
• Letter to PSCs regarding ID verification,
• Checklist of headline points for ECCTA, and
• Note to directors – summary of key issues under the ECCTA.

We have also added a new template, Overview of the IDV regime, which can be attached to letters sent to directors/PSCs explaining the regime.

The information pages relevant to IDV have also been updated.

Given the IDV regime is now live, directors and PSCs would be well advised to voluntarily verify their ID as soon as possible in advance of the company’s next confirmation statement. These letters will help companies undertaking this process both to inform directors/PSCs and facilitate the process of voluntary verification.

Companies House guidance in relation to IDV is available here.