How new Companies House ID requirements are working in practice

Rollout of the mandatory ID verification requirements for directors (trustees) and people with significant control (PSCs) commenced on 18 November 2025 and it is expected that more than 7 million people will go through the ID verification process.  A couple of months later, what have we found out about the process? 

The new requirements

All trustees and PSCs must verify their ID for Companies House. An individual who has completed the verification process will receive a personal code which must be provided to Companies House at the required time.

From 18 November 2025 confirmation statements must contain all of the trustees' personal codes and cannot be filed without them.  If trustees do not verify their ID in time, the company confirmation statement cannot be filed and will become overdue.

Individuals will need to register with the Gov.UK One Login Service and follow the online steps to verify their ID. This seems to be simplest when an individual uses a smart phone and a biometric passport but the website offers other options such as the use of a post office to complete the process.

If individuals don’t have the required information or documents for the Gov.UK service, some authorised corporate service providers (ACSPs) are offering ID verification services.

PSCs must provide their personal codes to Companies House either during the first 14 days of the their birth month or, if earlier, within 14 days of the confirmation statement using new Companies House form VS01 or online here: Provide identity verification details for a person with significant control (PSC) - GOV.UK

All new trustee appointments notified to Companies House must contain the personal code of the trustee being appointed.

All new PSC notifications will require the personal code of the individual to be provided to Companies House within 14 days.

For new companies, the personal codes for all directors and PSCs must be provided as part of the registration application.

ID verification status

Companies House now displays the ID verification status of trustees and PSCs, including an individual's deadline for ID verification and confirmation as to whether their ID requirements are complete. 

Failure to file / enforcement

Companies House is already taking a more active role as the regulator and has been issuing statutory notices to companies that fail to file on time. Failure to file a confirmation statement as a result of a failure to verify ID will lead to prompt commencement of enforcement action from Companies House in relation to both the late filing and the failure to verify ID.

A failure to file a confirmation statement is an offence that can lead to daily default fines. It is also an offence (for both individuals and the company) not to comply with ID verifications requirements on time.

What if problems with ID verification are preventing a charitable company from providing personal codes at the required time?

You can tell Companies House about exceptional circumstances which are preventing ID verification statements for trustees from being filed. If Companies House accepts the representation it will pause enforcement action to give you time to address the problem and file.

The form can be found here: Make a representation for not filing an identity verification statement - Make a representation – GOV.UK

PSCs can make a request to Companies House using a separate online form (or by paper form VS01) for a 14 day extension to provide their personal codes, here: Request to extend the identity verification deadline for a person with significant control (PSC) - Request to extend the identity verification deadline for a PSC – GOV.UK.

The request should include supporting evidence e.g. a screenshot of an attempt to verify. 

What other changes will there be?

These aren’t the only changes taking place at Companies House as a result of the Economic Crime and Corporate Transparency Act 2023.

• Registers: from 18 November 2025 there is no longer a requirement for companies to hold registers of directors, directors' addresses, secretaries and PSCs. However the information must continue to be registered with Companies House and kept up to date. Companies can no longer choose to hold information about its officers on the central register held by Companies House.
• Member list: There will also be a one-off requirement for companies to provide Companies House with a full shareholder list. This is likely to also apply to members.
• ID verification: requirements will apply to relevant legal entities (corporate PSCs: known as RLEs) and to those filing on behalf of a company (e.g. a school governance professional, company secretary or a firm filing on behalf of its clients). RLEs will need to designate a 'Relevant Officer' (who will be a member or director of the RLE) to verify their ID. The details of the Relevant Officer will need to be provided to Companies House and must be kept updated. Anyone who is not a trustee but files on behalf of a company will need to have their ID verified before they can make filings. Some professional services, such as law and accountancy firms will be able to file on behalf of companies if they register as an ACSP.
• Accounts: by 1 April 2027 accounts can only be filed using commercial software. This means that accounts can no longer be filed through web-filing or by post. Companies House has introduced a new web page to help companies to find a suitable commercial software here: Find software for filing company accounts - GOV.UK.