July 27, 2026 What the Law Society’s IDV guidance reveals about ‘reasonable excuse’
The Law Society’s guidance on confirming identity verification to Companies House may appear narrow at first glance. For law firms and other intermediaries, its value is broader. It shows how the profession is responding as Companies House moves from a largely trust-based filing model to one that expects evidence, judgement and a clearer record of reliance.
Caution where practice is unsettled
The guidance is not about how to verify identity. It is about the narrower, practical question of how a legal adviser can be comfortable confirming to Companies House that identity verification has taken place. Before providing such confirmation, firms need to know what they are relying on and why that reliance is reasonable.
That is a real change in filing culture. A point that might previously have been accepted on client assurance alone may now need a Companies House confirmation, screenshot, personal code record or similar evidence. As filings become more controlled, firms will need clearer rules on what they accept, what they retain and when reliance should be escalated.
The ROE parallel
The same instinct appeared in the Law Society’s 2022 guidance on the Register of Overseas Entities. There, it warned firms not to treat statutory verification as equivalent to ordinary anti-money laundering client due diligence. Verification required reliable, independent evidence.
The context is different, but the pattern is clear. When advisers are asked to support a statement to Companies House, the Law Society moves quickly from process to proof: what was checked, what evidence supports it, who is comfortable with it and what record will remain if the filing is questioned.
The ROE guidance also drew a clear line between government guidance and legal comfort. That matters here too. Even where the administrative route appears simple, firms and intermediaries may still need a stronger evidential basis before making a statement connected to the register.
What the guidance reveals about evidence
The guidance shows how a narrow Companies House confirmation can become a wider evidence question. The issue is not whether advisers trust their clients, but whether they can later show why it was reasonable to rely on a particular confirmation, code, screenshot or record.
That matters because presenter restrictions are likely to create more judgement calls: what evidence is enough before filing, which exceptions need escalation and what record should remain if the filing is later queried.
This is not about taking the most cautious position every time. It is about turning professional judgement into a repeatable standard: clear enough to apply consistently and robust enough to explain if challenged.
The same logic is likely to spread
The current guidance is limited to identity verification confirmations. It does not settle the presenter regime or future filing restrictions, but the same logic is likely to apply more widely.
As third-party filing becomes more controlled, firms will need clearer positions on reliance, evidence and responsibility: what is requested and retained, who signs off exceptions and how new requirements are explained to client teams.
These are questions of governance as much as law, affecting workflows, client communications, retention, risk appetite and the division of responsibility between lawyers, company secretarial teams and external filing support.
The challenge is to turn broad regulatory obligations into working standards that can be applied consistently. Firms do not need the most cautious position in every case, but they do need to explain the position they take.
Why the guidance matters beyond IDV
The significance of the Law Society guidance is not confined to IDV. It reveals a wider professional response to ECCTA: where the rules leave room for judgement, practice is moving cautiously. Where liability is uncertain, evidence becomes central.
The lesson for law firms and other intermediaries is straightforward: Companies House reform is changing who can file, what must be confirmed and what evidence firms need before they are comfortable making those confirmations.