Who will need to have their identity verified?
Identity verification will become compulsory for the following individuals:
- Directors, regardless of their nationality or country of residence;
- PSCs (including individual officers of a registrable relevant legal entity (RLE));
- Anyone filing documents at Companies House on behalf of a company.
The government also intends that IDV will be required for members and PSCs of limited liability partnerships. Whilst it is expected that implementation dates for LLPs will accord with that for companies, this has yet to be confirmed.
When does IDV need to be completed?
Companies House has published an indicative timeline and separate guidance which details when IDV must be completed, depending on an individual’s role:
- By autumn 2025, IDV will be mandatory for directors and PSCs on new company incorporations and for new directors and PSCs of existing companies.
- By autumn 2025, a 12-month transitional period will begin, requiring existing directors and PSCs to verify their identity as part of the annual confirmation statement process.
- By spring 2026, only an ID-verified officer or employee of a company, or an ACSP (or its officers or employees), will be able to file a document at Companies House on behalf of a company.
From 8 April 2025, anyone can choose to verify their identity before it becomes a legal requirement later in the year.
How can an individual verify their identity?
As explained in separate Companies House guidance, individuals can verify their identity free of charge directly through Companies House, via the GOV.UK One Login service, or indirectly through an ACSP. If using the Companies House route, identity can be verified online, using a mobile phone app or web browser, or face-to-face at a designated post office. The documentation that is acceptable depends on which route is used. For anyone with a current UK passport or a current overseas passport that has a biometric chip, verification using the app or website may be the easiest route.
As an alternative, individuals can use an ACSP to verify their identity on their behalf, for which there may be a charge. Only individuals or entities that are supervised by one of the UK’s anti-money laundering supervisory bodies can register as ACSPs with Companies House, which launched its ACSP registration service on 18 March 2025. The ACSP route will be suitable for anyone who is unable to use the Companies House route, for example, non-UK directors and PSCs who do not have a biometric passport.
Once an individual’s identity has been verified, Companies House will issue them with a unique identifier number, which will need to be included on filings at Companies House when IDV becomes mandatory. Directors, for example, will need to provide this code when a confirmation statement is filed or when they are appointed.
Individuals will usually only need to undertake the verification process once, even if they hold multiple directorships and are also PSCs.
Consequences of failure to verify identity
When identity verification becomes mandatory later in 2025-26, directors and PSCs who fail to verify their identity within the time required will commit a criminal offence (as will the company). An individual whose identity has not been verified will be unable to be appointed as a director.
What action should I take now?
Company directors and PSCs are advised to make themselves familiar with the upcoming changes and to consider undertaking IDV during the current voluntary phase in order to avoid delays that may occur when IDV becomes mandatory.
Client Alert 2025-106
