The 26 October 2025 marked two years since the Economic Crime and Corporate Transparency Act 2023 (ECCTA) received Royal Assent. Even after extensive coverage, its sweeping reforms continue to matter for those responsible for running UK companies—directors and officers alike.
From 18 November 2025, Companies House introduced mandatory identity verification for all Persons with Significant Control (PSCs), Directors, members of LLPs, general partners of limited partnerships, and relevant officers of Registrable legal entities (RLEs). This marks the start of a 12-month transition period for existing directors and PSCs to comply.
To support the public, on 17 November 2025, Companies House issued guidance on non-compliance with the mandatory identity verification requirements [1].
This article explains:
Verification can be completed in two ways:
Once verified, individuals receive a unique personal code. This code is essential for future filings and should be kept secure. What is important is that there is only one code required for an officer who holds positions in various UK companies as a Director/Member of LLP/general partner/PSC or someone acting on behalf of an RLE.
The rules differ depending on whether you are a new or existing director or PSC. From 18 November:
Please find the link to the PSC Companies House website here.
Companies House guidance adopts both supportive and punitive approaches:
Supportive measures
Companies are encouraged to comply with the requirement voluntarily. To that end, companies can receive support and advice from the Companies House helpline. Companies House is running an information campaign to raise awareness of the requirements, which may include sending emails and letters directly to companies.
Punitive measures
We have yet to see Companies House in action, however, generally, Companies House can enforce compliance through prosecution, referral to the Insolvency Service and apply financial penalties (para 5.1). While deciding whether non-compliance merits a punitive action, Companies House is likely to consider a wide range of factors. The guidance states that if a person or company has committed three or more offences over the five-year period, their failure is likely to be considered serious (para 5.3). The enforcement action might be paused for up to two months if mitigating circumstances are presented (para 6). Companies House can also annotate the public register (para 5.6) – diminishing public trust in the company or even disqualifying the director if they continue to act without verification (para 5.4).
Conclusions
Identity verification is now a legal requirement for all officers of a company. Whether you are a newly appointed Director or have acted as one for years, this requirement must be complied with. Non-compliance will result in serious consequences, including criminal liability and reputational damage.
The safest approach is to act promptly and ensure your details are verified. Contact our Company Secretarial team if you need assistance.
[1] [2] Companies House approach to non-compliance with mandatory identity verification – GOV.UK
Provide identity verification details for a person with significant control (PSC) – GOV.UK
Do you need an ACSP to help verify your identity?
Greenwoods are now an ACSP and can support you on your ID&V journey with a simple and efficient process.
Please find out more here: Simplifying your ID&V journey
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