Every director and person with significant control of a UK company must now verify their identity with Companies House, and the 12-month transition period for existing office-holders runs out in mid-November 2026. This article explains who is covered, how verification works, what the first prosecutions show and what company boards should be doing before the window closes.
What changed on 18 November 2025?
According to GOV.UK guidance, identity verification became a legal requirement from 18 November 2025. The same guidance is blunt that the date “is not a deadline”: it marks the start of a 12-month transition period in which companies are expected to get all directors and people with significant control (PSCs) verified by their due dates.
The change comes from the government’s wider push for corporate transparency. A register that anyone can search is only as reliable as the identities behind it, and verification is designed to make it harder to file under a false or borrowed name. For a business owner, it turns what was once an administrative formality into a personal legal obligation.
Who has to verify, and by when?
Companies House set out the timing in its announcement of the rollout. In summary:
| Person | When verification is due |
|---|---|
| New director | Before incorporating a company or being appointed to an existing one |
| Existing director | Confirmed with the company’s next annual confirmation statement during the transition period |
| Existing PSC | Within a 14-day window that depends on their circumstances |
| Later phases | Limited partnerships, corporate directors, corporate members of LLPs and officers of corporate PSCs, at dates still to be set |
The PSC window varies. A person registered as a PSC after 18 November 2025 has the period start on the date of registration. An existing PSC who is also a director has it start on the company’s confirmation statement date. An existing PSC who is not a director has it start on the first day of the birth month shown on the register, so someone born in March 1990 would see the window open on 1 March 2026, according to Companies House.
Because the existing-director route is tied to the confirmation statement, a company’s own filing calendar sets the practical date. The fixed point is the end of the 12-month transition period, which falls in mid-November 2026.
How does a director actually verify?
There are two broad routes, both described by GOV.UK.
Directly, through GOV.UK One Login
The online route is free. With a GOV.UK One Login, a person can use one of these photo documents:
- a biometric passport from any country (UK passports issued after 2006 are biometric);
- a UK photo driving licence, full or provisional;
- a UK biometric residence permit or biometric residence card;
- a UK Frontier Worker permit.
The person also needs their current address and the year they moved in. Each email address can be used to verify only one identity, so two directors cannot share a login.
People without suitable photo ID who live in the UK have alternatives: bank or building society details together with a National Insurance number and security questions, or a visit to a Post Office after entering their photo ID details online first.
Expired documents are treated differently by document type. Expired passports are not accepted. A UK driving licence issued by the DVLA is accepted if it expired in the last 90 days, and a residence permit, residence card or Frontier Worker permit is accepted if it expired in the last 18 months. Expired documents cannot be used for the bank or Post Office routes.
Through an authorised corporate service provider
An accountant, solicitor or other professional supervised for anti-money-laundering purposes can verify a person on their behalf, provided the person supplies suitable ID documents. Companies House calls these firms authorised corporate service providers.
What is a personal code, and why does it matter?
Once verified, a person receives an 11-character personal code, according to GOV.UK. The code belongs to the individual, not to the company or any company they work for.
The code is what links a verified person to each filing. A director has to provide it in the company’s next confirmation statement, and for new appointments it goes in with the appointment filing or the incorporation. PSCs provide it within their 14-day window.
Practical points from the guidance:
- Someone who verified through One Login can find the code under “Manage account” after signing in to Companies House with the same email address. Those who verified after 8 July 2026 were also sent it by email.
- Someone verified through a service provider has the code emailed to the address the provider gave.
- The code should be kept safe, but can be shared with someone filing on the person’s behalf, such as an accountant.
- If a code may have been shared or compromised, Companies House can issue a new one by email and cancel the old one, but the person has to contact Companies House to ask.
What happens to directors who do not verify?
The Insolvency Service has already begun to prosecute. According to a GOV.UK press release published on 17 September 2026, the City of London Magistrates’ Court dealt on 16 September 2026 with what the release describes as the first Insolvency Service prosecutions for identity verification offences.
The three cases show how the offences are framed:
| Director | Company | Penalties | Position on verification |
|---|---|---|---|
| Jill White | White (Reading Properties) Limited | Fine £166, costs £85, surcharge £66 | Completed in early September 2026, about nine months after the requirement began |
| Marc Dillon | White (Reading Properties) Limited | Fine £307, costs £85, surcharge £123 | Had verified, but did not stop White acting while unverified |
| Modinat Banjo | J Isogony Apparel Limited | Fine £80, costs £85, surcharge £32 | Completed on or around 28 May 2026 |
Ms White and Ms Banjo were convicted of acting as directors while unverified and of failing to file confirmation statements on time. Mr Dillon was prosecuted for failing to prevent Ms White from acting while unverified. A second director who has verified can therefore still be exposed if a colleague has not.
The arithmetic on the release’s figures checks out: fines of £166, £307 and £80 total £553; costs of £85 for each of the three defendants total £255; and surcharges of £66, £123 and £32 total £221. Together that is £1,029. In a company’s accounts that is a small sum, but each outcome is a criminal conviction rather than a late-filing penalty.
Daniel Hart of the Insolvency Service said in the release: “There is no option to opt out.” Martin Swain of Companies House added that “identity verification is not optional.”
Why is this a business decision and not just a form?
For small firms, verification can look like a task for whoever handles the paperwork. But the obligation sits with each individual, and the consequences reach the business.
First, filing. The Insolvency Service cases involved late confirmation statements as well as unverified directors, and the two are linked because the statement is where an existing director confirms verification. A missed or late filing is the kind of administrative lapse that can pile up quietly. As explained in why growing businesses still run out of cash, small operational slips tend to surface at the worst moment, and a stalled filing is no different.
Second, governance. Many private companies have several directors and a handful of PSCs, some of whom may be family members, investors or former colleagues who rarely engage with the business. Somebody has to know who has verified and who has not.
Third, counterparties. Lenders, suppliers and customers use the public register to judge who they are dealing with. An accurate, verified register supports trust in the same way that clean accounts do, and it sits alongside the compliance topics covered in how corporation tax marginal relief works for companies of different sizes.
How many people still need to act?
Companies House said in its announcement that it expected 6 to 7 million individuals to verify by mid-November 2026, and that more than 300,000 people had verified during the voluntary period that began in April 2025. Those were projections and early figures at the time of the announcement, not a current count of progress, and readers wanting up-to-date numbers should check the latest Companies House management information.
The scale matters because a rush near the end of any transition period tends to create queues and avoidable errors. Verification itself is quick for most people with a passport or licence. Companies House cited an average completion time of 2.4 minutes for the ID-checking app between 18 March and 30 June 2025. The delay usually comes from tracking down a director who is abroad, unreachable or unaware of the requirement.
A simple checklist for company boards
Boards of small companies can work through a short list:
- List every director and PSC, including those who rarely take part.
- Check which of them has verified and which has not.
- Agree whether each person will use One Login or a service provider.
- Make sure each person’s personal code is held securely and can be given to whoever files.
- Check the date of the next confirmation statement and the PSC windows.
- Keep a record of the process, so there is evidence if anyone later asks.
Later phases will bring in other kinds of entity, so firms with partnerships, corporate directors or corporate PSCs should watch for further dates from Companies House and not assume that the current deadline is the last.
Conclusion: treating verification as routine governance
Identity verification has moved from proposal to enforced law. The mid-November 2026 end of the transition period is the point after which it will be harder to argue that there was time to comply, and the first court cases show that late compliance can still result in a conviction. For most directors the check itself takes minutes; the real work is making sure everyone connected with the company has done it.
This article provides general information, not personalised financial or legal advice. Rules, deadlines and penalties change.
Sources: GOV.UK; Companies House; Insolvency Service
