Companies House Identify Verification – Impact on your business

The list of affected roles and scenarios is extensive, and dependent on your company’s legal structure and ownership.  Some common examples are:

1. Directors of a UK registered company.
2. Persons with significant control (PSC).
3. Those who make filings for a company.
4. Director equivalent roles in other corporate structures.  For example, new or existing members of a limited liability partnership (LLP), or a new or existing general partner (GP) of a limited partnership (LP).
5. A relevant officer or PSC of a Registerable Legal Entity (RLE)
6. A director of an overseas company required to register a UK establishment.

The registration process is available on a voluntary basis already; however, enforcement is taking place in three tranches.

• If you are intending to take up a new position as a director (or equivalent) or PSC, verification of identity will be incorporated into the appointment and incorporation processes from the 18^th November.
• If you are an existing Director (or equivalent) or PSC you will need to have verified your identity:
  • Director (or equivalent) before your next confirmation statements after the 18^th November.
  • PSC only before the 14^th day of your birth month if that falls after the 18^th November 2025.
  • Director and PSC before your next confirmation statement AND within 14 days of submission of your confirmation statement.

If you are in another role verification requirements will be introduced at a later date, but it is advisable to get your personal code as soon as possible.

There are several ways to verify your identity.

Instruct an ACSP, like Anderson Strathern, to verify your details. Certain regulated professionals (such as a solicitor or accountant) may be registered with Companies House as an Authorised Corporate Services Provider to facilitate the verification process and make the filing on your behalf. In some instances, these advisers may already hold sufficient information to register on your behalf.  They may also use ID verification software to register you quickly and conveniently.  This may also be a useful avenue where there are many individuals to be verified.  This service may attract a fee.

There are two self-service methods of verification.  First you can verify your details directly through GOV.UK One Login, completing the electronic verification process with your biometric passport or driving license.  Alternatively, you can begin the verification process online, completing it in person at your local Post Office. Companies House does not currently charge a fee for these self-verification methods.

Aside from the practical impact of being unable to make company filings, there are criminal sanctions being introduced by ECCTA.  These may be significant and can include criminal charges, fines and imprisonment.