Has your charity done all it can to prepare for the mandatory requirements to verify trustee identity?
One significant outcome of the Economic Crime and Corporate Transparency Act 2003 (ECCTA) is the introduction of mandatory ID verification for company directors, persons with significant control (PSCs), and individuals filing on behalf of a company.
With mandatory ID verification for directors and PSCs less than a couple of months away, charitable companies need to prepare for the change.
How to verify your identity for Companies House
All directors of charitable companies will be required to verify their ID. The government's free-to-use identity verification service launched in April 2025, allowing individuals to apply for verification.
You can access the site here. Individuals will only need to register once and will be given a unique code, which is used to link their verified ID to their appointment/s at Companies House. This unique code will be required for future filing in relation to the individual (e.g. a new director appointment).
Some professional firms that have registered as authorised corporate service providers (ACSPs) will be able to verify identity for individuals (usually as a paid-for service).
When will your charity be affected?
Charitable companies will need to provide the unique codes of all of their trustees (directors) with the submission of the charity's first confirmation statement after Autumn 2025, or on appointment of a director.
Any new companies incorporated from Autumn will need their directors (and PSCs if applicable) to be verified.
Identity verification for directors and PSCs will be a legal requirement and it will be an offence for individuals to be unverified directors, and for companies to be led by unverified directors.
What should the board do?
All trustees and PSCs should be aware of the requirement to verify their identity.
We would encourage all trustee board members to verify their ID as soon as possible if they have not already done so. Each trustee should make a note of their unique ID and have it to hand when the Charity's confirmation statement date approaches.
Include identity verification as part of your trustee recruitment processes so that when a new trustee is successfully appointed, no issues arise regarding this requirement.
A failure to have a verified ID as a company director will be an offence. In addition it will be an offence for a company to be directed by an unverified director.
By Autumn 2026 the transition period will have ended and compliance action against companies or individuals who have not complied, can begin. ECCTA has given Companies House enhanced powers so that it can have a more active role in tackling corporate crime, so trustee boards should take the new requirements seriously.
What's next
These changes are part of a suite of updates being made by Companies House in phases and Companies House is providing updates on its website here.
According to its current timetable, from Spring 2026, stricter controls on document filing will be introduced by extending mandatory ID verification to individuals filing documents with Companies House. Any individual filing for a company (who is not a verified director or PSC) will need to be an employee or officer of the company and have their ID verified. Alternatively, they must be registered as an ACSP acting on behalf of the company.
In support of the move to a fully digital service, from spring 2027, changes will be made to the way in which accounts are filed with Companies House, so that they are only filed online through commercial software. In addition, the filing for small and micro-entity accounts will be streamlined, with companies no longer able to file 'abridged' accounts.