Companies House reforms – verification of identity

This insight is part of our Legal Business News | Winter 2025 series. Explore the full series at the end of this piece.

In this article, we look at the identity verification requirements in the Economic Crime and Corporate Transparency Act 2023 (the act), which received royal assent in October 2023 and comes into force in stages.

The act aims to improve transparency of UK companies primarily by reforming the role of Companies House. One of the key issues in the act for companies is the requirement for certain individuals to have their identify verified before making Companies House filings.

Overview of the coming companies house reforms to verification of identity

New company directors, appointed on incorporation of the company or subsequently, must have their identity verified before notifying Companies House of their appointment as a director. During a transitional period, existing directors will be required to have their identify verified before the company files its next confirmation statement after the new rules take effect.

Limited liability partnership (LLP) members and people with significant control of an LLP must comply with the identity verification procedures. If a member of an LLP is a corporate entity, all the directors (or equivalent) of that entity must verify their identity.

The act contains a prohibition on any individual acting as a director unless either their identity has been verified or they fall within an exemption (yet to be published), and the act places an obligation on companies to ensure that its directors have had their identity verified.

People with significant control (PSCs) must also be verified on becoming a PSC on incorporation of companies or LLPs and if they become a PSC following incorporation. Where a PSC is a company or other registrable entity (a relevant legal entity or RLE), one of its officers must be verified.

Any individuals, companies and firms making Companies House filings on behalf of their clients must register with Companies House as an authorised corporate service provider (ACSP). The ACSP regime is for third parties such as accountants and legal advisers that are already registered with a supervisory body (e.g. ICAEW, FCA, SRA, etc) for anti-money laundering purposes and have an existing obligation to carry out customer due diligence checks on their clients.

In addition, anyone delivering documents to Companies House, either on their own behalf or on behalf of another party, must have their identity verified unless they are an employee of an ACSP acting in the course of their employment.

When an individual’s identity, including an ACSP, has been verified, they are allocated a unique identifier number allowing Companies House to maintain a database of verified individuals. Provided individuals maintain their verified status, they do not need to have their identity re-checked each time they make a Companies House filing, or a Companies House filing is made relating to them.

The intended (but not final) timetable for Companies House to implement the identity verification procedures is as follows:

• By Spring 2025, Companies House intends to carry out checks on ACSPs to authorise them to carry out identity verification services and allow individuals to complete voluntarily identity verification.
• By Autumn 2025, Companies House intends to make identity verification compulsory for directors and PSCs on incorporation, and for newly appointed directors and new PSCs, and begin a 12-month transition period to require identity verification for existing directors and PSCs.
• By Spring 2026, Companies House intends to require identity verification for individuals filing any document at Companies House, and to require a third party filing on behalf of a client to be registered as an ACSP.

Moore Kingston Smith is committed to supporting clients in complying with the act, including with the identity verification requirements, and will register as an ACSP when the registration process opens.

If you have any questions about the proposed changes, please contact Harry Dronfield, Mark Thomas or your usual Moore SGD Law contact.

This article is provided for information purposes only. It does not constitute legal advice and should not be relied on or treated as a substitute for specific advice relevant to particular circumstances.

Read the rest of our Legal Business News | Winter 2025 series here: