The next major change coming into effect is the introduction of identity verification requirements for filings made at Companies House. This article provides a summary of the new requirements and the steps that companies need to take to comply. For a summary of the other changes introduced by the Act, see our earlier article here.
Who will the identity verification requirements apply to?
Companies House will require identity verification to be provided by:
- all new directors and people with significant control (PSCs)
- all existing registered directors and PSCs
- those filing documents at Companies House on behalf of a company
Identity verification will also apply to other registration types. For example, any members of a limited liability partnership (LLP) will also need to verify their identity.
How can identity be verified?
Individuals will be able to voluntarily verify their identity directly with Companies House through GOV.UK One Login. There are 3 ways to prove your identity with GOV.UK One Login:
- with the GOV.UK ID Check app: this involves uploading a photo of your ID documents such as a passport and driving licence and scanning your face.
- by answering security questions online about things like your mobile phone contract, and any bank accounts, credit cards, loans or mortgages you may have and entering details from a UK passport, UK photocard driving licence or a current account with a UK bank or building society.
- at a Post Office: you will be asked to enter details from your photo ID on GOV.UK and go to a Post Office that offers ‘in branch verification’, where they will scan your photo ID and take a photo of you.
Identity verification can also be provided through an Authorised Corporate Service Provider (ACSP). ACSPs are individuals or organisations, such as solicitors, undertaking an anti-money laundering (AML) supervised activity, which have registered with Companies House.
When do the identity verification requirements come into effect?
From 25 February 2025: Anti-money laundering supervised firms (including solicitors) can apply to become ACSPs. ACSPs will also be known as Companies House authorised agents.
From 25 March 2025: Individuals will be able to voluntarily verify their identity directly with Companies House.
By Autumn 2025: Providing identity verification to Companies House will become compulsory on incorporation and for new directors and new PSCs. A 12-month transition period will begin for submitting identity verification for existing directors and PSCs. This will be required when the company’s next confirmation statement is submitted to Companies House.
By Spring 2026: Identity verification will be required for presenters filing any document on behalf of a company and third-party agents filing on behalf of a company will be required to be registered as an ACSP.
By the end of 2026: Additional filing requirements will be introduced for limited partnerships.
By the end of 2026: The transition period for requiring identity verification will be complete and compliance activity will be started against those who have failed to complete identity verification where required to do so.
What are the consequences of failing to carry out identity verification?
Failure to comply with identity verification requirements will be an offence. There will be a range of consequences for companies, including financial penalties, being unable to make statutory filings, the registration of a new company being rejected and a company being struck off the register. Unverified directors may also be disqualified.
It will be an offence for a person to deliver a filing or statement to Companies House that is false, deceptive or misleading in a material particular “without reasonable excuse”. There is also a new aggravated criminal offence for any person to knowingly deliver a filing or statement to Companies House that is false, deceptive or misleading in a material particular. This would apply to any statement made in relation to identity verification.
If you have any queries about anything mentioned in this article, please contact Amber Monaghan or get in touch with one of our corporate solicitors today.
