More changes are afoot for charitable companies: is your charity ready for the new Companies House ID verification requirements?
The recent introduction of the Economic Crime and Corporate Transparency Act 2023 (ECCTA) has given Companies House stronger powers to ensure the data held by the registrar is accurate and to improve the integrity of the register of companies.
Trustees of charitable companies may already have seen some of the changes being made by Companies House, such as the additional requirements for an annual confirmation statement.
Companies House is now introducing mandatory ID verification for directors, persons with significant control (PSCs) and individuals filing on behalf of a company.
How and when will ID need to be verified?
It is intended that individuals will be able to register with an account in order to verify their ID and we expect that individuals will be able to register here in due course.
Once an individual has their ID verified, they will be issued with a unique identifier that can be provided to Companies House when required and linked to a verified account.
Companies House has stated that individuals can voluntarily verify their ID from 8 April 2025. (Do check the Companies House web pages for any updates to the implementation dates as their timetable has been changed more than once.)
According to the current timetable (which has been recently updated by Companies House), from Autumn 2025, individuals will need to have verified their ID before the company confirmation statement is due (if they are an existing director or PSC), before their appointment as a director, or before they submit any filings on behalf of the company.
A PSC can provide their unique ID to Companies House upon notification of their status, but if they do not, Companies House will contact the individual to verify their identity. They must verify their identity within 14 days of notification to Companies House. If a PSC does not have their identity verified within 14 days they will be marked on the register as 'not verified' and could be subject to penalties for non-compliance.
The consequences of non-compliance can range from an individual having their status marked as 'unverified' to criminal proceedings (which could result in a fine). Future incorporations may be rejected, and an unverified individual will not be able to make statutory filings, having a knock-on negative effect for the operation of the charity (in terms of its attractiveness for donors or grant-makers for example). For trustees this means they could be prohibited from acting as a director. A director who is disqualified from being a company director is automatically disqualified from acting as a trustee.
Changes to the requirements of the confirmation statement - from Autumn 2025
On submission of a company confirmation statement, Companies House will ask for confirmation that all the trustees (directors) of the charity and any PSCs have had their identity verified. Companies House will then be able to link the individuals to their verified account.
It will be an offence for a director not to have their identity verified and for a company to be directed by an unverified director.
Filing
From Spring 2026 no individual will be able to file on behalf of a company unless:
- they are a director of that company (and have had their ID verified)
- they are a PSC of that company (and have had their ID verified)
- they are an employee or officer of that company (and have had their ID verified) or
- they are registered with Companies House as an 'Authorised Corporate Service Provider' (or 'Authorised Agent'), filing on behalf of a company.
Authorised corporate service providers
An authorised corporate service provider (ACSP) is a body authorised to verify the ID of individuals and file with Companies House on behalf of a company, at the same time making a statement to the effect that the ID of the individual has been verified (in accordance with the requirements of the relevant regulation made under the ECCTA). ACSPs will be organisations (or individuals) that undertake anti-money laundering activity in their normal course of business, such as solicitors or accountants. The service to register ACSPs is due to launch on 18 March 2025.
Once registered, ACSPs will be able to verify the identity of directors and PSCs.
Prepare your board
Charitable companies should do what they can to understand and prepare for these changes. Here are some suggestions:
- Keep an eye on the Companies House web page which is providing updates on the changes, links to important information and timelines.
- Make sure the list of directors of the charity is correct on Companies House.
- Encourage all trustees (and PSCs) to voluntarily set up a verified account when the service becomes available later this month.
- On appointment of new trustees, request that the appointee sets up a verified account as soon as they can (you may even choose to do this as part of your trustee recruitment process). From Autumn 2025 Companies House will not register a new director if they do not have a verified account.
- Ensure anyone who files on behalf of the charity (such as a company secretary who is not a director, or an employee with filing responsibility) has also set up an account. Contact PSCs and ask them to do the same.
- Consider a briefing paper or training update for your board so that the obligations for the trustees and the charity are clear.