Companies House Identity Verification: are address checks required?

Companies House advise that ACSPs must meet a minimum identity verification standard for each identity check they complete, and have issued the following warning:

If your identity checks do not meet the required standard, we could suspend or stop your business from acting as an authorised agent.

However, whilst referring to the importance of address verification, neither legislation nor Companies House guidance specifically state that address checks are always required to meet the minimum identity verification standard. Instead, ACSPs must exercise their own judgement.

The starting point for reaching a decision is to assess the risks presented in confirming an individual applicant’s identity and making Companies House filings on their behalf. However, there are other factors to weigh. This article briefly discusses what legislation and Companies House guidance have to say on the matter, before considering the benefits and potential downsides of address verification.

What does the legislation say?

The Registrar’s (Identity Verification by Authorised Corporate Service Providers) Rules 2025 provide the regulations that apply to ACSPs completing identity checks. The regulations require that any individual subject to Companies House identity verification (‘the applicant’) provide the following details:

• A contact email address.
• Their home address (and previous home addresses if they have lived at their current address for less than 12 months).
• Biometric or photographic evidence (if available) that can be assessed for likeness against the individual.

The legislation also stipulates the documents that can be used as evidence, depending upon the approach taken to identity verification (Option 1 or Option 2).

Option 1 is the preferred approach

The legislation states that applicants “must use Option 1” if this is possible. Option 1 requires that:

• the applicant provide biometric evidence (such as a biometric or machine-readable UK passport) or photographic evidence (such as a UK photocard driving licence); and
• the ACSP validate cryptographic features.

If Option 1 is followed, the legislation only requires one document to be provided, with the main purpose being to validate identity (rather than address).

Option 2 requires additional documents to be provided

Option 2 provides a route for ACSPs that are not using an identity checking service capable of validating cryptographic features. The applicant must provide two pieces of evidence from the list of documents prescribed by the legislation. Many of these documents also provide evidence of the individual’s current address and therefore validate both identity and address.

What does Companies House say?

Companies House provide guidance on how to meet the identity verification standard required to ensure compliance with the legal responsibilities of an ACSP. The minimum requirement includes completion of each of the following 6 steps when verifying the applicant’s identity:

1. Obtain key personal data: full names and former names, date of birth, email address and home address (including an address history for the last 12 months).
2. Get documents to verify identity: the preferred document is a biometric passport.
3. Validate evidence is real: if the evidence is being checked by a person they must have been trained to detect forged documents.
4. Check identity is real, and it belongs to the applicant: the document must confirm name and date of birth, and the applicant must match the photo on the document.
5. Keep records of the identity check for 7 years.
6. Decide if the work done is sufficient to verify the person’s identity to the required standard.

Whilst step 4 of the Companies House guidance only requires ACSPs to verify identity, it also advises that

To lower the risk of you accepting a synthetic identity, you should ask to see additional documentation if the identity documents provided do not confirm [the applicant’s] address history for the last 12 months…if [the applicant] cannot provide documentation that confirms their address history…consider whether to continue verifying their identity.

In addition, step 6 requires that ACSPs must be able to “explain and evidence why [they] have concluded that the steps…taken [to verify identity] are appropriate”.

ACSPs must therefore conduct their own risk assessment and judge whether they have obtained adequate assurance to verify an individual’s identity. For example, where the director is a longstanding client, the risks involved with verifying their identity and making filings on their behalf may be reduced. In contrast, a new client, a non-UK resident director or PSC, or a residential address that looks unusual, are all higher-risk features that may prompt an ACSP to obtain additional assurance (such as an address check) before they feel comfortable enough to verify the identity.

Completing an address check may offer benefits

Neither the legislation nor Companies House guidance expressly state that address checks are required to meet the minimum identity verification standard. Arguably therefore, separate address verification could be considered an optional requirement. However, Companies House comments do suggest that they consider verification of the residential address of directors and PSCs to represent best practice. Similarly, all ACSPs must be registered with an AML supervisory body and compliance with the more stringent identity verification standards of AML legislation may be better achieved by adopting a more comprehensive approach that includes address checks.

Completing an address check, particularly if this requires a second piece of personal data (such as a current utility bill), allows cross-checking of the identity against additional databases and associations beyond simply name and date of birth. It enhances the accuracy of the identity verification process and reduces the risks that the ACSP might be exposed to identity fraud.

Confirming the applicant’s residential address provides additional assurance that the individual is who they claim to be and may expose a deliberate attempt to conceal true identity or provide false details. An address check may be particularly worthwhile if there are features that elevate the risks of the identity verification request. Reliance on manual checking; provision of lower quality or easily forged documents (i.e., non-biometric); documents that are not very current or that have expired; or remote verification that does not include any real-time ‘live’ checking of the applicant, are all features considered to elevate the risk of an identity check.

Confirming the individual’s residential address enables the ACSP to build a more accurate risk profile of the client. For example, it may identify that a client is resident in a high-risk jurisdiction, or that the address is invalid, inaccurate or non-residential.

ACSPs must be able to evidence a level of checking that is sufficient to justify verification of an applicant’s identity to Companies House. In addition, many ACSPs will also be regulated entities subject to Anti-Money Laundering (AML) regulations. Completing thorough checks, that include additional elements such as address verification, provides confidence that the standards required by an AML Supervisory Body or Companies House are likely to be met. For this reason, many ACSPs may consider it best practice to verify the residential address of directors and PSCs, and identity checking services often include address checks as standard.

ACSPs subject to AML regulations will be used to verify both the identity and address of relevant directors and beneficial owners. Verification of residential address is a key component of Customer Due Diligence (Know Your Client) work – both for new clients and as part of ongoing checks for a longstanding client. ACSPs may consider it helpful to complete address checks for directors and PSCs when verifying their identity for Companies House, if this also contributes to work required under AML regulations.

For clients that are considered higher risk, perhaps because of the profile of services provided to them by the ACSP (i.e., payroll, plus company formations, plus address services, plus accounts filing, etc.,), address checks can aid both risk assessment and Enhanced Due Diligence processes. For example, address checks enable the director or PSC to be linked to other database sources, such as credit checks and official sanctions lists, and they may also be helpful when conducting adverse media screening.

Identity verification regulations permit Companies House to require the applicant to answer additional questions or provide particular evidence before their application is concluded. Completing address verification at the same time as identity checks may avoid additional enquiry and the delay that results.

There could be downsides to selecting an address check

Most directors and PSCs will be familiar with providing evidence of their residential address to meet the AML obligations of banks, accountants and solicitors acting on their behalf. However, a small minority may be resistant to providing evidence of their residential address, considering it sensitive personal data. They may be anxious that their residential address will be included on the public register, and additional communication may be required to reassure them that this is not the case. However, ACSPs are also advised that if an applicant is unusually resistant to providing evidence of their residential address, this could be considered a red flag that they may pose the threat of identity fraud.

Under GDPR residential address is considered personal data, and as such must be handled lawfully and transparently. There must be a valid legal basis for processing residential address data (compliance with the obligations of identity verification for Companies House or AML regulations provides this). The individual must be advised of the data being collected and why, how it will be used and stored, their rights to access or erase their personal data, and details of any third party entities involved in the data processing.

Each time residential address information is requested and processed, the potential for release of this sensitive data to the public domain is heightened. Therefore, if the applicant subject to identity verification is a low-risk longstanding client, and their address has been separately authenticated in the recent past (perhaps as part of Know Your Client checks), further address checks may not be warranted. In this case, best practice is for the ACSP to document the reasoning behind their lighter touch approach. This provides an audit trail of the decision-making process and demonstrates compliance with minimum identity verification standards should Companies House query this in future.

Adding an address check may entail the payment of an additional fee to the identity verification platform. It may also complicate or delay the process (if for example the applicant finds it difficult to provide documentation to support their recent residential address history).

Whilst address verification does provide an additional layer of assurance, it cannot negate all risks of fraudulent identity. ACSPs might consider the quality of the address documentation provided and the possibility it could have been forged and attempt to validate it in context with other information provided by the applicant.

Conclusion: balancing risks and rewards

There is no straightforward answer to the question of whether every Companies House identity verification should also include an address check. The answer is dependent upon multiple factors, and not least the ACSPs own assessment of the risks presented when verifying the identity of an individual and making Companies House filings on their behalf. However, the ICAEW in their Insights article of 29 May 2025 describe the reputational damage that may result for a firm not completing adequate identity checks, with the following sober warning:

If Companies House removes an ACSP from the register, all of your clients have to get themselves re-verified, so clients will know…

ACSPs will need to carefully balance the rewards and downsides of completing address checks as part of their identity verification process and weigh this against the risks that they might otherwise fail to meet the Companies House minimum identity verification standard.