The Economic Crime and Corporate Transparency Act: The New Identity Verification Requirements

The Economic Crime and Corporate Transparency Act 2023 is considered to be the largest overhaul of company law in recent years. The aim of the Act is to combat fraud and money laundering by strengthening company oversight, improving transparency, and empowering Companies House to verify and challenge suspicious information.

This largest change being introduced is the mandatory identity verification for any individual involved in company governance. The legal obligation to have identification verification applies to all company directors, members of limited liability partnerships (LLPs), people with significant control (PSCs) and anyone who submits documents to Companies House on behalf of a company.

From 18 November 2025, any newly appointed director, member of an LLP and/or PSC (whether in existing companies or companies being newly incorporated) must complete their identity verification before their appointment as director or member of LLP or PSC can be legally recognised. This means that no individual can act as a director or member of an LLP or be appointed a PSC unless their identity has been verified.

Once verified, the individual will be issued a personal code that is to be used when registering or filing with Companies House.  This code will need to be retained as part of your personal and corporate records as it will be needed when the Company file their Confirmation Statements.

Companies House will require confirmation that the identity verification has taken place on confirmation statements filed from March 2025. Therefore, any company whose confirmation statement filing deadline falls in the year will need to ensure their directors and PSCs are verified before or at the time they file their Confirmation Statements.

If your Confirmation Statement date is approaching you need to act now!

How to get verified

Individuals can verify their identity through Companies House directly and will need a GOV.UK One Login to do so. GOV.UK One Login will ask questions to determine the method the individual should use to verify their identity. It will depend on what device the individual has and what identification documents they individually hold and is done through a mobile app, online security questions or through a participating Post Office branch.

Alternatively, individuals can verify their identity with an Authorised Corporate Service Provider (ACSP). Solicitors and accountants can register to be a ACSPs which allows them to verify the identity of individuals and carry out filings on behalf of companies. All ACSPs will be regulated under UK Money Laundering Regulations and can be ideal for individuals who are based overseas, do not have the required UK or EU identity documents or incur difficulties with the digital verification processes outlined above.

Consequences of not being verified

Failure by an individual to verify their identity can have serious consequences for both the individual and the company.

Companies seeking to appoint unverified individuals risk having their filings rejected by Companies House or the incorporation of a company blocked entirely. Delay in filings or missed filings can result in fines for the directors and officers, the company itself may be struck off the register and dissolved and in some circumstances, the directors may be disqualified from holding future company positions.

Acting as a director, member of an LLP or as a PSC without having their identity verified will constitute a criminal offence.

It is anticipated that Companies House will annotate public registers to show individuals as being ‘unverified’. This is a clear signal of poor governance and will act as a major red flag to lenders, customers, suppliers, investors and regulators.

It is expected that there will huge influx of verifications in the coming months. It is therefore advised that all directors, members of LLPs, PSCs or persons who make filings on behalf of companies take action now to reduce the chance of delay, disruption and potential penalties.

Woodfines LLP is a registered Authorised Corporate Services Provider and can assist both individuals and companies with verifying identity. If you would like assistance or have any questions around the new identity verification requirements, please reach out to CorporateCommercial@woodfines.co.uk