Company directors are being reminded that identity verification with Companies House is now a legal requirement, following the first prosecutions brought by the Insolvency Service for failing to comply.
The warning comes as Companies House approaches the end of the 12-month transition period for the new identity verification requirements introduced under the Economic Crime and Corporate Transparency Act 2023.
First directors convicted for failing to verify their identity
On 17 September 2026, the Insolvency Service and Companies House announced the first court prosecutions relating to the new identity verification requirements.
Three directors were convicted at the City of London Magistrates’ Court after failing to comply with their legal obligations.
In one case, a director continued to participate in board-level decision making and signed company accounts while she had not completed identity verification. Another director, who had verified his own identity, was prosecuted because he failed to take reasonable steps to prevent the unverified director from continuing to act.
The third director had also continued acting as a director without completing the required verification.
The individuals were fined and ordered to pay costs and victim surcharges. Companies House confirmed that the cases demonstrate that identity verification is not optional and that directors who continue to act without verifying their identity may face investigation and prosecution.
Importantly, the Insolvency Service stated that in these cases the directors had been given multiple opportunities to comply before enforcement action was taken.
What is Companies House identity verification?
Identity verification is part of a major programme of Companies House reforms introduced by the Economic Crime and Corporate Transparency Act 2023.
The aim is to improve the accuracy and reliability of the Companies House register and make it more difficult for companies to be established or controlled using false or stolen identities.
The requirement applies to:
- company directors
- people with significant control (PSCs)
- certain equivalent roles, including members, general partners and managing officers
- directors of overseas companies registered in the UK
- Authorised Corporate Service Providers (ACSPs), such as authorised agents.
When do directors need to verify their identity?
Mandatory identity verification began on 18 November 2025.
There is a 12-month transition period for existing companies.
New directors
Anyone appointed as a new director from 18 November 2025 must complete identity verification before acting as a director.
The requirement also applies when incorporating a new company.
Existing directors
Existing directors do not all have the same verification deadline.
Instead, during the transition period, they must verify their identity and provide their Companies House personal code as part of the company’s next confirmation statement.
This means directors should not simply assume that they have until a particular calendar date. Their individual deadline is linked to the company’s confirmation statement filing.
With the 12-month transition period approaching its conclusion, directors who have not yet completed the process should act now rather than waiting for their next filing deadline.
What happens when you verify?
Once identity verification has been successfully completed, the individual receives a unique Companies House personal code.
The code is personal to the individual rather than the company and is used to link the verified identity to the relevant company records.
For directors, the personal code must be provided when the company’s confirmation statement is filed.
Companies House guidance confirms that a confirmation statement will not be accepted unless the identity verification requirements for all directors have been satisfied.
If you are a director of more than one company, you will need to provide your personal code for each relevant company role.
How do you verify your identity?
For most individuals, identity verification can be completed online using GOV.UK One Login.
You will generally need an acceptable form of photographic identification, such as:
- a biometric passport
- a UK photo driving licence, including a provisional licence
- a UK biometric residence permit
- certain other accepted identity documents.
Identity verification through GOV.UK One Login is free.
Alternatively, identity verification can be completed through an Authorised Corporate Service Provider (ACSP).
What happens if a director does not verify their identity?
This is where the recent prosecutions are particularly important.
It is unlawful for a director to continue acting as a director without completing the required identity verification.
Failure to comply can result in enforcement action, including:
- criminal prosecution
- fines
- financial penalties
- restrictions on future appointments
- annotations on the Companies House register
- in serious cases, director disqualification.
Companies House has said that it may also refer cases to the Insolvency Service.
The recent prosecutions show that the legislation is not simply an administrative requirement. There is now evidence of enforcement through the courts.
Directors have responsibilities for other directors too
One important point highlighted by the recent cases is that directors need to consider the position of their fellow directors.
It is not necessarily enough for one director to have completed their own verification.
Companies House states that a company may also be in breach where one of its directors remains unverified. The Insolvency Service has also made clear that directors may have responsibilities to ensure that an unverified individual does not continue to act as a director.
This is particularly relevant where a company has several directors.
What about People with Significant Control (PSCs)?
The new requirements also apply to People with Significant Control (PSCs).
A PSC is generally an individual who owns or controls a company, for example through holding more than 25% of its shares or voting rights, or having other significant control over the company.
PSCs have their own identity verification requirements and deadlines.
Once verified, a PSC must provide their Companies House personal code and confirm that their identity has been verified. The timing of the 14-day period for PSCs depends on their circumstances and their relationship with the company.
It is therefore important that companies consider both directors and PSCs, rather than focusing solely on directors.
What should directors do now?
If you are a company director, we recommend checking that you have:
- Completed your Companies House identity verification.
- Obtained and retained your Companies House personal code.
- Provided your personal code when required for each company in which you are a director.
- Checked whether you are also a PSC and, if so, complied with the separate PSC requirements.
- Ensured that any other directors of your company have also completed their verification.
- Kept your Companies House information up to date, including your registered email address and details of directors and PSCs.
It is worth completing the verification process sooner rather than leaving it until your confirmation statement is due.
Don’t ignore Companies House correspondence
Companies House has set out a staged approach to enforcement.
The process includes informing companies about their obligations, providing guidance and reminders, and taking enforcement action where businesses or individuals fail to comply.
Where identity verification requirements are not met by the relevant deadline, Companies House may issue a default letter explaining the offence and warning that enforcement action may follow. Enforcement options include financial penalties, referral to the Insolvency Service and prosecution through the courts.
Companies House has also stated that it will take account of exceptional circumstances where appropriate, but this should not be relied upon as an alternative to completing the verification process.
How Saint & Co can help
The introduction of mandatory identity verification is another significant change to the responsibilities of company directors and PSCs.
For many directors, completing the verification itself should be relatively straightforward. The important thing is to understand when it needs to be done and what information needs to be provided to Companies House afterwards.
At Saint & Co, we can help our company clients understand the new Companies House requirements and ensure that the necessary information is dealt with as part of their company compliance.
If you are unsure whether you have completed your identity verification, what your deadline is, or what you need to provide to Companies House, please contact your usual Saint & Co adviser.
Further information
The official Companies House identity verification guidance is available on GOV.UK.
Verify your identity for Companies House – GOV.UK
The Insolvency Service and Companies House announcement regarding the first prosecutions is also available here:
Directors warned to verify identities following first prosecutions – GOV.UK
Lindsay Farrer
Managing Partner
22 September 2026
