Preparing for the new Companies House ID verification requirements

These reforms are not specific to schools. They aim to deter those wishing to use any company for illegal purposes and to improve transparency, trust and accuracy of information on the Companies House register.

This update is aimed at all incorporated schools, whether or not they are also charitable.

What's changing?

From 18 November 2025, Companies House will require identity verification for:

Directors (who may also be trustees or governors)
Persons with Significant Control (PSCs) - those with a 'beneficial interest' also referred to those who own or control the company.
Companies House guidance sets out the full definitions: PSC requirements for companies and limited liability partnerships, which include those who own more than 25% of the shares or voting rights.
Anyone filing documents on behalf of the school (e.g. your governance professional or Company Secretary).

How will ID be verified?

All relevant individuals will need to register for an account with Companies House. Once verified, they will be issued with a unique identifier code linked to their verified status, which should be stored safely.

Voluntary verification started in April 2025 and mandatory verification will commence on 18 November 2025. At this point, anyone filing a return on behalf of the school, acting as a director, or identified as a PSC must have their identity verified.

If a PSC does not proactively provide their verified ID, Companies House will contact them directly. They will then have 14 days to comply, or risk being marked as 'not verified', which may result in penalties.

Implications for schools

Failure to comply could have serious consequences, in that:

Individuals may be disqualified from acting as directors.
Unverified individuals will be prohibited from filing statutory documents.
Filings could be rejected, delaying compliance and affecting your school’s public standing.
Criminal penalties, including fines, may apply in some cases.

Confirmation statement requirements (from Autumn 2025)

Charitable companies will need to provide the unique codes of all of their directors with the submission of the charity's first confirmation statement after 18 November 2025, or on appointment of a director or identification of a PSC.

Filing changes from Spring 2026

Only the following will be able to file notices and returns on behalf of the company:

Verified directors or PSCs.
Verified employees or officers of the company.
Authorised Corporate Service Providers (ACSPs) – typically regulated professionals (e.g. solicitors, accountants) who can verify identity and file documents on your behalf.

ACSP registration opens on 18 March 2026.

Steps for schools to take now

To prepare your school, ensure compliance and avoid disruption:

Check and update Companies House records to ensure your current board of Directors and PSCs are correctly listed.
Monitor updates from Companies House – implementation dates have changed before.
Encourage directors and PSCs to register and verify their ID as soon as possible and before the 18 November deadline.
Update your recruitment process to include ID verification for new directors.
Ensure staff responsible for filings also complete verification.
Consider using an ACSP if you outsource compliance or governance support. We offer these services if of interest.
Brief your board on the upcoming changes – a short paper or training session can clarify roles and responsibilities.

Final thought

These changes bring added compliance demands, but also mark a clear move toward stronger governance and greater transparency. Preparing early will help your school stay ahead of requirements, avoid unnecessary disruption, and maintain the confidence of regulators and key stakeholders.

These changes are part of a suite of updates being made by Companies House in phases.