Updating data at Companies House for identity verification

While this is thankfully largely a one-off task – Companies House has indicated that the circumstances for re-verification of any individual will be limited – it could be a challenge in managing time, deadlines and data integrity for many accountants, and even when the client is self-verifying at Companies House.

To ease the process of identity verification, a necessary preliminary step is to ensure the details of each person are recorded correctly at Companies House. This matters because:

• Identity verification is likely to fail if incorrect data from the existing Companies House record are used to complete the check
• Even if the identity check itself is successful and the individual obtains a personal code from Companies House, when this code is supplied to the Registrar for any particular director, PSC or LLP member role the person’s details on the record will be at least partially checked against those supplied when confirming the identity check. If the details on the public record are incorrect or inconsistent with those used as part of the identity verification, this may mean submissions – including the first confirmation statement from 18 November 2025 – are rejected
• Aside from the specific task of identity verification, the Economic Crime and Corporate Transparency Act has handed Companies House more powers with respect to querying and challenging information on the public register, and then to enforcement and financial penalties for observed failings

Therefore, before completing identity checks for clients – or encouraging them to undertake a check themselves directly at Companies House – it will be prudent for accountants to check the data on the public record, and make updates where necessary.

From our experience of Companies House data, we’d suggest reviewing the following.

Are the right people recorded on each company?

The first step in checking the data for any company is to ensure the right people – particularly directors and PSCs – are recorded. That should include:

• Ensuring the appropriate PSCs are recorded accurately based on shareholdings, voting rights and other elements of control
• Removing duplicates of PSCs (and directors). There are thousands of companies on the public register that currently have the same person recorded twice in the same role, most commonly two PSC records with different control reasons
• Promptly submitting the appointment of any current directors not yet recorded and removing any directors who no longer serve

For many companies and limited liability partnerships (LLPs), this will be an opportunity to review who is appointed as an officer, and potentially streamlining the list of those appointed as directors or LLP members. If terminations are processed promptly ahead of 18 November, it will avoid the need for identity verification of those individuals. However, it’s still important that anyone performing the role of a director or LLP member is validly appointed and recorded as such on the public record.

Definitely fix clients’ dates of birth

When a personal code is submitted to Companies House relating to a particular officer/PSC role, Companies House will check the date of birth of the individual on the existing public register matches that recorded against the identity check. Any inconsistency will result in a failure of the submission which tries to report the personal code. That could mean, for example, that the entire confirmation statement fails if a director’s date of birth is not consistent with that verified on an identity check.

Historic mistakes with dates of birth on the public record may relate to:

• Simple errors in receiving the correct date of birth from the client, recording or reporting it to Companies House
• Issues relating to accidental American-style dating (month/day/year)
• Instances where someone apparently knew the month but not the date of birth and so incorrectly chose to report the date of birth as the first of a month
• Remember that a single person will potentially have a date of birth recorded separately for each of their roles across each company they are involved with. If a single person has different dates of birth recorded on different roles in the same company, or across different companies, a fix will be needed somewhere

Usually, a date of birth correction will require second filing of the original Companies House submission. Elsewhere, we look in detail at how to correct a date of birth at Companies House.

Probably fix clients’ names

When a personal code is submitted to Companies House relating to a particular officer/PSC role, Companies House is likely to check the name of the individual on the existing public register matches the name recorded against the identity check.

Companies House has given the facility, when a personal code is confirmed in a confirmation statement or other submission, for an explanation to be provided as to why the name on the public record is different to that on which an identity check was undertaken. In future, this will help support cases where someone changes their name – on marriage or for other reasons – without needing again to complete the identity verification process.

In the early days of the new regime, it is unclear how rigorously Companies House will validate that a name recorded for a director or PSC matches that which has been verified. To avoid the possibility of submissions being rejected, it would therefore be prudent to ensure an individual’s name is correct and consistent across all their roles on all the companies in which they are involved.

The following may cause issues if they’re not fixed:

• Simple spelling mistakes on names
• If an individual’s middle names are not included on the public record
• Diacritical marks, including hyphens in surnames, etc.
• If a commonly used name, rather than the individual’s name on their identity documents, has been recorded – e.g. ‘Bob’ rather than ‘Robert’
• If an individual has got married or otherwise changed their name without an update being made to the Companies House record
• It’s sensible to review that an individual’s name is consistent across their different roles and across different companies. Sometimes the same person’s name will have been submitted inconsistently, especially if notified at different times. Similarly, an update on a change of name may have been completed for one role (e.g. a director appointment) but not another (e.g. as a PSC), or completed for one company but not another.

Using Inform Direct, it’s easy to change a person’s name at Companies House.

Possibly fix clients’ residential addresses

It has not been directly confirmed by Companies House whether the requirement to verify identities extends to validating the residential address of the individual. In the absence of such certainty, our observation is that accountants acting as ACSPs are choosing to include such a check.

It is indeed possible that, when a personal code is submitted to Companies House relating to a particular officer/PSC role, Companies House may undertake some form of validation.

Many accountants are therefore choosing to use this opportunity to ensure clients’ residential address details are correct and consistent with identity verification completed where that process includes an address check.

To ensure residential addresses on Companies House’s record are correct and identity verification has the best chance of success, the following types of historic issues may need to be reviewed:

• If an address has not been formatted correctly when submitted to Companies House (for example with the house number and/or road name included twice)
• If a purchased serviced office address has incorrectly been recorded as an individual’s residential address
• If a business address (or their accountant’s office address) has been recorded at Companies House as the individual’s residential address. While this might historically have been seen as helping an accountant maintain control over communication, an incorrect residential address recorded at Companies House is likely to cause problems (and may obstruct the process of identity verification)
• If an individual has moved house but their residential address has not been updated
• An individual will potentially have a residential address recorded separately for each of their roles in a company and across different companies. Therefore, it’s possible over time that these have become inconsistent, where errors have been made or submissions missed, and now should be reconciled

Using Inform Direct, it’s easy to update an individual’s residential address.