From 18 November 2025, all individual PSCs need to verify their identities. In time, the requirements will extend to Relevant Legal Entities (RLEs), but there is currently no timescale for that. Here we look at the requirements for new and existing PSCs as at 18 November 2025, and the role of the new VS01 form as a verification statement in the process.
Identity verification can be undertaken by the individual directly at Companies House or via a third party Authorised Corporate Service Provider (ACSP). As part of that process, whichever option is chosen, the individual claims a unique Companies House personal code, identifying them as an individual in the eyes of the Registrar.
Then, for each company or LLP on which the individual acts as a PSC, this personal code must then be supplied back to Companies House. This requirement applies from 18 November 2025.
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Newly appointed PSCs from 18 November 2025
For newly appointed PSCs from 18 November 2025, the personal code must be supplied at the time the PSC is notified to Companies House. It can be supplied:
- For PSCs notified as part of forming a new company, on the existing incorporation form (IN01 or equivalent)
- For new PSCs added to existing companies, as part of the existing form PSC01 (or, for LLPs, form LLPSC01)
- If not supplied on these forms, on the new standalone VS01 form, which we understand must be submitted within 14 days of the original submission
A personal code must be supplied even when the effective date the person became a PSC is before 18 November 2025. If the notification is delivered on or after 18 November 2025, whatever the date the person became a PSC, identity verification must be undertaken and a personal code confirmed as part of the appointment.
The notification is on a per appointment basis. So even if a personal code has already been submitted for an individual on one company, it will need to be confirmed again as part of the notification of a new PSC on another company or LLP.
This requirement to supply a personal code as part of reporting a new individual PSC will now be a continuing part of company secretarial compliance.
Existing PSCs as at 18 November 2025: use the VS01 form
Existing PSCs on the public register as at 18 November will also need to have their identity verified and obtain a personal code from Companies House. However, there is a (complex) transitional regime determining when in the year from 18 November 2025 they must supply this code to Companies House.
Despite earlier expectations, and unlike company directors, existing PSCs do not supply their personal code to Companies House on the first confirmation statement from 18 November 2025. Instead, they do so on the new VS01 form. (VS stands for ‘verification statement’).
The requirement for existing PSCs to supply form VS01 is on a per appointment basis. So if someone is a PSC of five different companies as at 18 November, they will need to submit five different verification statements, one for each appointment.
When does a PSC need to submit form VS01 for an existing appointment?
This is the most complex bit, where Companies House have tied themselves in knots.
In short, a PSC should submit the form when Companies House say they should.
For each PSC appointment, the individual will be given a window of 14 days (starting on a ‘Date from’ and ending on a ‘Date to’), in which the VS01 form must be submitted. The basis of when the 14 day window falls depends on whether Companies House identifies that a PSC is also a director of the same company:
- If the PSC is also a director of the same company, their 14 day window to submit form VS01 begins on the company’s next confirmation statement made up date and lasts 14 days. This assumes that Companies House have managed to identify that an individual is both a director and PSC of a company.
- If the PSC is not also a director of the company, their 14 day window to supply the VS01 form is in the month of their birth, starting with those born in December. Regardless of the precise date of their birth, the window begins on the 1st and ends on the 14th of that month.
Much depends here on whether Companies House successfully match director and PSC records on any single company. We have already seen examples where a difference in name records means the same person acting as a director and PSC has not been successfully matched at Companies House. In that case, it appears that the PSC will be required to submit the verification statement in the first 14 days of their birth month.
Some companies will have confirmation statements overdue as at 18 November 2025. That means the next confirmation statement made up date is in the past. In this case, for a PSC matched as a director, Companies House appears to be using a VS01 window based on the anticipated first post-18 November 2025 confirmation statement made up date. So, for example, if at 18 November 2025 the ‘next’ confirmation statement should be made up to 4 September 2025, we expect a ‘matched’ PSC’s window to open on 4 September 2026, as that will be the first made up date from 18 November 2025, even though another confirmation statement needs to be filed in the meantime. (Note that the first confirmation statement filed from 18 November 2025, even if it relates to an earlier made up date, will need to include personal codes for directors.)
A single individual may be a PSC on a number of companies. On some companies, they might also be a director, but not on others. As well as a requirement to submit form VS01 for each company on which they are a PSC, this may mean the same PSC:
- Will need to submit the verification at different times, for example where they are also a director of different companies with different confirmation statement due dates; and
- Will need to submit multiple instances of form VS01 at the same time, for example if they are a PSC of multiple companies of which they are not also a director. In that case, they will need to submit a form for each company or LLP in the first 14 days of their birth month.
The window for each PSC record will be available to view online at Companies House. As we stream the details from the Registrar, Inform Direct users can see all the dates at a glance, either per company or for all your companies in a summary report, making it easier to comply.
Unless a PSC’s date of birth is corrected at Companies House, we understand that from 18 November 2025 a PSC’s window for submission will not change. Therefore, even if a confirmation statement is filed early with personal codes supplied for directors, the 14 day window for a PSC ‘matched’ with a director record to submit their verification statement will remain aligned with the original confirmation statement timing, rather than being brought forward.
We therefore expect it will not be possible for PSCs to file their verification statement early, even though that would make a lot of sense to allow! In practice, we would imagine that if an existing PSC as at 18 November 2025 does not file the VS01 form within their allotted window, a later submission would still be accepted – but that is still to be validated, and the late filing might incur penalties for non-compliance.
What needs to be submitted on the VS01 form?
The new form VS01 is short and simple. You need to include:
- To identify the PSC, details such as the person’s name and partial date of birth
- The individual’s Companies House personal code
- Where required, a reason why the individual’s name on the public record does not match the name under which their identity was verified. (This might be, for example, because the person has got married and changed their name since their identity was successfully verified.)
How do you submit form VS01 to Companies House?
An individual PSC can file form VS01, although we imagine the task will often be undertaken by an officer of the company or their accountant.
A new service will be available on Companies House’s website to file the VS01 form.
You can also use Inform Direct to submit the new VS01 form:
- In Inform Direct, you can check the windows in which the Companies House verification statement must be submitted for each PSC. You can also receive reminders of submission windows that are forthcoming.
- Optionally, accountants registered as ACSPs can use our identity verification tool to verify the identity of individual PSCs.
- With the individual’s Companies House personal code entered in the software, you can submit the VS01 form at the touch of a button without entering any details again.
- Once Companies House’s systems are stable and providing predictable responses to submissions, we will be enabling users who wish to save themselves more time to automate the submission of the verification statement. In this way, if you have already entered the personal code, Inform Direct will automatically file the VS01 once the submission window opens.
We understand that a paper form will only be made available in very exceptional cases.
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