Upcoming company law requirements for Academy Trusts: prepare for new ID verification rules
The Economic Crime and Corporate Transparency Act 2023 is bringing important changes that will affect how academy trusts manage and report key company information through Companies House.
These reforms aim to improve the accuracy of the data held on the companies register and enhance corporate transparency.
Academy trusts (which are companies limited by guarantee), will be directly impacted, particularly through new mandatory identity verification requirements and changes to confirmation statements.
What’s changing?
Companies House will now require identity verification for:
- Trustees (ie directors, who some single academy trusts might refer to as 'governors')
- Persons with Significant Control (PSCs) – this could include a Trust's members or other individuals depending on your structure, and
- Anyone filing documents on behalf of the Trust (eg your Governance Professional or Company Secretary).
How will ID be verified?
Individuals will need to register for a verified account via Companies House. Once verified, they will be issued with a unique identifier linked to their verified status.
Voluntary verification started on 8 April 2025 and mandatory verification will commence this Autumn. At this point, anyone filing on behalf of the Trust, acting as a Trustee, 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 Academy Trusts
Failure to comply can have serious consequences:
- Individuals may be disqualified from acting as directors, which would prevent them from serving on the Trust's board.
- Unverified individuals will be prohibited from filing statutory documents.
- Filings could be rejected, delaying compliance and affecting your Trust’s public standing.
- Criminal penalties, including fines, may apply in some cases.
Confirmation statement requirements (from Autumn 2025)
When submitting your annual confirmation statement, you must confirm that all Trustees and PSCs have had their identity verified. This will enable Companies House to cross-reference individuals with their verified IDs.
Filing changes from spring 2026
Only the following will be able to file on behalf of the Trust:
- Verified Trustees or PSCs
- Verified employees or officers
- Authorised Corporate Service Providers (ACSPs) – typically regulated professionals (eg solicitors, accountants) who can verify identity and file documents on your behalf
ACSP registration opens on 18 March 2025.
Steps for Academy Trusts to take now
To prepare your Trust, ensure compliance and avoid disruption:
- Check and update Companies House records to ensure your current board of Trustees and PSCs are correctly listed.
- Monitor updates from Companies House – implementation dates have changed before.
- Encourage Trustees and PSCs to register and verify their ID once the portal is live.
- Update your recruitment process to include ID verification for new Trustees.
- Ensure staff responsible for filings also complete verification.
- Consider using an ACSP if you outsource compliance or governance support.
- 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 Trust stay ahead of requirements, avoid unnecessary disruption, and maintain the confidence of regulators and key stakeholders.