Navigating compulsory identity verification and beyond

Wherever you’re at on your journey, there’s still time to get ahead.

For accountants, there’s a number of key decisions to make:

• Whether your firm will act as an Authorised Corporate Service Provider (ACSP)
• If you are verifying client identities as an ACSP, whether you will do so based on the client providing physical evidence (being conscious of the strict requirements from Companies House to undertake this approach) or rely on an electronic service
• How you will interpret the identity verification requirements, including whether you will undertake a check of each client’s residential address
• Where required, selecting an electronic service for identity verification

Depending on the answers to those questions, a holistic plan will need to map out a new workflow including some or all of the following:

• Identifying who needs to be verified and when
• Communicating verification requirements to clients and options to fulfil them
• Undertaking identity verification for each person (or, if your firm is not doing checks, supporting clients as they navigate the process the verifying their identity using Companies House’s online service)
• If you are acting as an ACSP, supplying details of successful checks via Companies House’s ACSP portal
• Obtaining personal codes from clients, ahead of them being required
• Managing the process of submitting personal codes to Companies House at the right time for each individual role (as a director or PSC) on each company

Sharing expectations with clients early, and giving them time to act ahead of needing personal codes, is likely to be beneficial.

For many companies and LLPs, there will be more than one person for whom an identity check is required, even if you typically liaise with a single individual. In that case, you’ll either need contact details to communicate with each person affected, or a clear expectation that your single contact will shepherd other stakeholders into action.

For those accountants with a larger number of clients, the practice will need to decide how to divide the workload effectively, to avoid unnecessary duplication and ensure nothing is missed. You may also need to prioritise clients by deadlines.

Ensuring clients’ personal data is correct at Companies House will make the task of identity verification and confirmation of personal codes against individual director and PSC records a whole lot easier, whether you or your clients are doing the work.

An identity check is likely to fail if out of date or otherwise incorrect Companies House data is used to complete the check. Even when an identity check itself is successful, when the personal code obtained is supplied to Companies House, the personal details used for the check will at least partially be checked against the details on the public record for that director, PSC or LLP member. If the information is inconsistent, this may mean submissions are rejected.

Elsewhere, we look at what accountants can do to efficiently check the data on the public record and make updates where necessary.

From 18 September 2025, many submissions will require identity verification to be completed first. If they are filed ahead of 18 November 2025, it defers the identity verification requirement, so there is value in acting early.

Similarly, as it will be a requirement to verify the identity of all directors, LLP members and PSCs on companies and LLPs, you’ll want to check the individuals recorded are still the right people. That means you won’t risk the pointless exercise of having to verify the identity of people who are no longer involved, or only learning very late that there are additional individuals to verify.

As soon as possible, therefore, you should consider:

• Submitting appointments for any new directors or LLP members
• Terminating directors or LLP members who will no longer act as such
• Reviewing and updating PSC records, to ensure the right people are recorded
• Forming any planned new companies or LLPs
• If you know an early filing of a confirmation statement is necessary, for example to reflect current shareholdings on the public record after a corporate event, submitting that statement well ahead of 18 November
• Undertaking the company dissolution process for any companies that are definitely not required going forward

Potentially, therefore, the pending implementation of the new regime offers a good reason for accountants to check in with clients, review circumstances and perform a broader corporate health check.

We understand from Companies House that the first confirmation statement filed on or after 18 November 2025 will need to include personal codes for directors. That’s true even if the confirmation statement is made up to a date before 18 November.

That means, for example, that a confirmation statement that needs to be made up to 15 November, will not need to include personal codes if it is filed online on 16 November. The same confirmation statement, also made up to 15 November, delivered on 19 November would need to include personal codes for all directors.

The implication is clear. Unless you or your clients appreciate the extra work of identity verification, obtaining and submitting a personal code for all directors, get outstanding confirmation statements filed in advance of 18 November 2025.

The logical extension to the last point may be to file a batch of confirmation statements early and ‘reset the clock’ on when identity verification will be required for those clients until a year’s time, buying a bit of breathing space.

For example, many accountants are considering submitting all of the confirmation statements that would otherwise have been made up to dates in the period 18 November to 31 December before the new regime takes effect. All things being equal, that would mean the first confirmation statement under the new regime – when identity verification will need to be carried out and personal codes obtained and supplied – would be required a year from the current submission.

That could allow busy accountants a slower start to mandatory identity verification and otherwise updating their processes, and limit any potential negative impact on clients. Especially if the advent of the new regime proves challenging, this respite may be welcome for all – and mean you can ‘get ahead’ with the first round of confirmation statements which will fall under the new regime for which identity verification is required.

We should, however, be open about the limitations of this approach:

• You will need to act soon, most likely well ahead of 18 November. Companies House plans to provide a full list of dates on which personal codes are expected to be submitted in respect of existing companies, around four weeks in advance of the new regime taking effect. That would be around 21 October 2025. It’s possible that any attempt to amend a due date by filing after the dates are published, but before 18 November, will be ineffective.
• A change to the next confirmation statement date will only change the deadline for verifying directors or LLP members (whose personal codes are submitted as part of the confirmation statement) and PSCs who Companies House has ‘matched’ as a director (or LLP member) on the same company (or LLP). If the PSC is not also a director, or they are not successfully ‘matched’, their personal code will need to be submitted in the first 14 days of the month of their birth. Regardless of the date of the next confirmation statement, that would mean any such ‘standalone’ PSC born in December would need their identity verified and a personal code submitted to Companies House in the period from 1 – 14 December 2025.
• Deferring a large volume of confirmation statements will naturally have as its consequence a significant spike in submissions required (and identities to verify) in a year’s time.

In a lot of cases, it will be straightforward to verify the identity of the people on a company (or facilitate them to do it themselves via Companies House’s service). In a lot of companies, the single shareholder (and, therefore, PSC) will be the only director. As long as Companies House have successfully recorded them as the same person, this means:

• Only one identity verification will be required, and one personal code obtained
• The personal code in respect of the directorship will need to be submitted as part of the first confirmation statement submitted from 18 November 2025
• The personal code in respect of the same person as a PSC will need to be submitted within 14 days of the confirmation statement

However, not all clients will be quite so straightforward. To mitigate issues later on – and the potential for late filings, penalties and related challenging conversations with clients – it’s sensible to think about challenging clients well in advance.

In this context, any of the following might make a client company ‘challenging’:

• They are difficult to contact or generally unresponsive (in which case contacting them particularly early, detailing their options and action required, will be helpful)
• The people on the company who will require their identity verified will struggle with a technological solution (in which case manual verification of documents by an ACSP, if possible, or the option to verify identity at a post office may be useful)
• There are lots of directors or LLP members to verify. For example, many professional firms set up as LLPs have tens of members who will need to verified, and residents’ management companies sometimes appoint a director in respect of each flat or unit within the block. Unless an early decision is made to terminate the appointment of some of these officers, they will all need to verified and have their personal codes submitted as part of the first confirmation statement from 18 November 2025. Otherwise, the confirmation statement will fail. Even the process of communicating with so many stakeholders, many of whom will not usually play an active role in Companies House submissions, could be logistically challenging.
• The individuals who require their identity to be verified are non-UK individuals, for whom the range of options for identity verification may be more limited.

We hardly need to say this, but accountants can rest assured that Inform Direct is with you every step of the way on your journey to ECCTA compliance. We continue to engage with Companies House with the aim to deliver outcomes that make sense, and build technical content to guide our clients through the maze of requirements.

Our software will help accountants and others manage the new regime, whether you are acting as an ACSP and undertaking identity checks, or expecting your clients to check their own identity via Companies House’s online service:

• Accountants can record their ACSP registration details
• Use reports to plan which officers and PSCs must have their identity verified
• An ACSP can initiate identity checks for their clients to complete
• Carry out checks on existing officers and PSCs or new people
• Each officer/PSC completes a simple, step by step identity check
• View the current status of identity checks at any time
• Save the details of checks completed for compliance purposes
• Download successful check details to submit on the ACSP portal
• Enter personal codes received by the individual from Companies House
• Submit personal codes in Companies House submissions once required to do so