July 9, 2025 Why Act Now on Identity Verification
Identity verification is a central part of the UK’s corporate transparency reforms under the Economic Crime and Corporate Transparency Act 2023. The date for the phased introduction of mandatory verification has now been announced as November 18th.
“We encourage directors, people with significant control of companies (PSCs), and those filing information with Companies House to verify their identity during the voluntary window.”
Louise Smyth CBE, Companies House CEO
However, with seven million individuals needing to verify the advice from Companies House and the compliance industry is to not delay. Here’s why.
Over Seven Million People Will Need to Verify
The rules apply to a wide range of individuals:
- Company directors
- Equivalent roles such as LLP members, general partners and managing officers
- Directors of overseas companies with UK establishments and unregistered companies. Find out more here.
- People with significant control (PSCs), or relevant officers of corporate PSCs
- Individuals who file for companies (e.g. company secretaries) by Spring 2026)
Companies House estimates over seven million people will need to be verified, its largest compliance exercise to date. Even with the Companies House system investment, delays are possible as demand builds.
Verifications Will Be Front-Loaded
The compulsory verification date for directors is the first Confirmation Statement date of a company that the individual is a director of.
If you’re a director of several companies, the obligation starts with the first confirmation statement due. For that reason, verifications will be front-loaded, adding to potential bottlenecks, especially early on. It is not unreasonable to expect nearly 1 million people a month to need to register during November, December and into early 2026.
Deadline confusion
There is no simple, clear message for stakeholders of existing companies on when they need to comply because the deadline varies depending on their circumstances:
- Director of Company X – the confirmation statement filing date.
- Director and PSC of Company X – the confirmation statement filing date and 14 days after (respectively).
- PSC of Company X – the 14th day of your birth month.
Organisations wanting to ensure compliance will want to verify as part of a single exercise.
Verification Will Become a Barrier to Incorporation
From 18th November, no one will be able to act as a director or equivalent unless they have already been verified. In practice, this means you won’t be able to incorporate a company unless all key individuals have completed the identity process.
This marks a shift in how company formation works; verification will become a prerequisite. If you’re forming companies on behalf of clients or managing incorporations internally, this is something to plan for now.
As an Authorised Corporate Service Provider (ACSP), Elemental can support incorporations and identity verification in tandem, streamlining the process for clients and internal teams alike.
Choosing the Right Verification Route
There are three ways to verify:
- Online via GOV.UK
- In person at a designated Post Office
- Through an Authorised Corporate Service Provider (ACSP)
Not every option suits every person. Some won’t have the right documents for the government route. Others may want extra support, especially if they’re overseas or unfamiliar with the UK system. ACSPs can provide a more tailored, managed experience and take on the administrative burden. Enterprises wishing to consider ACSPs will want to factor in any internal supplier selection and onboarding processes.
This Is Not the Same as AML Checks
Although many firms already conduct Anti-Money Laundering (AML) checks, the Companies House identity verification regime is different. AML is risk-based and allows discretion; identity verification under ECCTA is rule-based and prescriptive, both in terms of who must be verified and what documentation is acceptable. Not all professional advisors are supporting their clients with identity verification. Elemental is supporting both new and existing clients with its Elemental Verify platform.
There Are Offences for Non-Compliance
Once the regime goes live, any unverified director or equivalent will be committing a criminal offence if they continue acting. Any company that permits this will also be in breach. On top of that, Companies House won’t accept the confirmation statement, meaning late filings, possible penalties, and reputational damage.
Identifying Who Needs to Be Verified May Take Time
In straightforward cases, this will be easy. For example, all listed directors. But things get more complex with PSCs, corporate structures, and overseas ownership. Even knowing where to look can be a challenge.
Start with your company’s PSC register, recent confirmation statements, or incorporation documents. In more complex structures, legal or governance teams may need to map out ultimate control or beneficial ownership to confirm who qualifies.
The Right Documents May Not Be to Hand
Regardless of the verification route, individuals must provide documents themselves. For some, this is as simple as uploading a passport. But others will need additional items, such as proof of address or proof of name change.
Tracking down these documents can take longer than expected, particularly if translations or certified copies are needed.
There is also a real risk that some individuals don’t have the right documents. For example, we know that for a material minority of biometric (or chipped) passports, the chip does not work. This could be because of water damage, overuse or just error. The passport will normally still work fine as a passport, but it will not be sufficient for this identity verification, as the chip cannot be checked.
By starting early, you have time to gather what’s needed and resolve any issues before they cause a delay. There can also be other unexpected issues, for example, where an individual’s name at Companies House does not match their ID.
Overseas Individuals Often Face the Greatest Hurdles
Verifying non-UK individuals frequently introduces extra complexity. They may be less engaged with UK compliance, unfamiliar with the process, or hold documents not recognised under UK rules. Language barriers, time zone differences, and unfamiliar formats can all slow things down.
If your directors, PSCs or filing agents include overseas individuals, now is the time to alert them. Early engagement allows time to explain what’s required and avoid them becoming a bottleneck.
In Summary
While identity verification is not yet mandatory, delaying action creates risk. By acting now, companies can identify who needs to be verified, ensure the right documents are in place, and choose the most appropriate verification route.
Elemental can help at every stage. As an Authorised Corporate Service Provider, we offer secure remote verification technology available 24/7, anywhere in the world. We support complex and overseas cases, provide a fully managed service for senior stakeholders, and can provide technical support. For existing clients, we can review your records to identify who needs to be verified.
To learn more about our verification service, please visit our Identity Verification Services page.
