
Mandatory ID verification will come into effect on 18 November 2025 - what do you need to do?
Have the trustees of your charitable company verified their identity for Companies House? Companies House has confirmed that the rollout for mandatory ID requirements will start on 18 November 2025.
After that date, company directors (trustees) will be required to provide their 'personal code' with the submission of the company's confirmation statement. Any new directors will be required to provide their code too. Any person with significant control (PSC) will also be required to verify their identity and provide their code to Companies House within 14 days of submission of the confirmation statement, or within the first 14 days of their birth month.
How to get a personal code?
Trustees and PSCs will need to verify their identity and there are two routes for doing that - one being the government's free to use online identity verification service, the other being through an authorised corporate service provider (ACSP) that provides an identity verification service.
The government's free to use identify verification service can be accessed here. Individuals will only need to register once to receive their 'personal code' - a unique code which is used to link a verified ID to Companies House records. The personal code will be required for all future filing in relation to that individual (e.g. a new director appointment).
Government service
Individuals will need to register with the Gov.UK One Login service. Those trustees with an existing Companies House account may be asked to link the two accounts.
Individuals should follow the online steps set out on the One Login website to verify their ID. This will be easiest for trustees who have a smart phone and a biometric passport but trustees can also use a UK photo driving licence, a UK biometric residence permit, UK biometric residence card or a UK frontier worker permit.
The smartphone will be required to scan the photo ID, and to scan the chip on the biometric passport (if applicable). The chip is contained within the symbol at the bottom on the front cover of a biometric passport.
Once the identity check is complete, the personal code will usually be generated immediately.
If individuals don’t have the information or documents for the online check, they may be able to continue the checks in-person at the Post Office (with bank or building society details and National Insurance number).
ACSP
If it is not possible for an individual to verify their identity through the government service or the Post Office then an ACSP offering identity verification services should be able to help. The ACSP is likely to charge for their service. VWV will not be offering an identity verification service for Companies House ID purposes, but there are plenty of providers who will offer the service.
Practical tips for trustees
- If you already have a Companies House log in: you will be prompted to link your Companies House account with your new One Login account. You will need to log in to both your Companies House account and your One Login account. In the future the accounts will be linked and all companies house accounts are transitioning across to One Login.
- If you are using your smartphone: don’t download the app until you are prompted to do so. Start by registering on the One Login website. It will then prompt you as to when you should download the app to follow the steps required using your phone. If you download the app too early, you risk creating two accounts.
- Keep a note of your personal code: it will not be emailed to you. You can however log on to One Login again to access your code.
- Companies House has opened a dedicated line for dealing with queries relating to use of the service: you can contact Companies House on 0303 1234 500 (select option 1 for One Login queries).
- Start the process sooner rather than later: it will be an offence to act as a director without verifying your identity and the confirmation statement cannot be submitted without the personal codes of all the trustees,. Late filing to Companies House can also incur penalties for company directors and companies. If for any reason you cannot verify your ID through the government service you will need to ask an ACSP to verify your identity. Allow time for this possibility.
- If you have a trustee or an employee who co-ordinates company filings: they should ensure they have each trustee's personal code in plenty of time before the confirmation statement is due. Similarly, gather the personal code of any individual who will be joining the board so that their appointment can be filed on time and without issue.
What can the charity do?
- Board briefings and reminders: update the board as to the requirements and encourage trustees to register for a personal code as soon as possible. Ensure that personal codes are available to the person filing on behalf of the charity so that there are no delays (and subsequent penalties) when it comes to company filings.
- On-boarding: ensure that in the recruitment of future trustees, individuals provide their personal code to the charity well in advance, so that their appointment can be recorded at Companies House.
- PSC: identify any individual PSCs and notify them of the requirement to verify their identity too.
- Deadlines: keep trustees aware of the deadlines, and stay up to date with guidance from Companies House here. Companies House will be publishing dates on the register highlighting when personal codes will be required. These dates are expected to appear from the 18 November, when the rollout begins.
- Information: there is plenty of information on the gov.uk website as to the process and requirements for identity verification. The link here explains who needs to verify their identity, and how.
Will VWV verify ID?
VWV will be an ACSP but will not verify ID.
What if we don’t do it?
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. Penalties can be imposed upon both directors and companies in relation to the offences. Companies House has new and enhanced powers which will make it a more active regulator. Trustee boards should take the new requirements seriously so as to avoid incurring penalties for offences.
For more information, please contact Penelope Straker in our Charity Law and Governance team.