Identity verification and other company law aspects of the Economic Crime and Corporate Transparency Act 2023 (ECCTA)

Companies House introduced the first step of its new identity verification reforms under ECCTA on 18 March 2025. We provide an overview of these identity verification changes and ECCTA's other significant reforms.

 

Identity verification

Timing

From autumn 2025, ECCTA will introduce mandatory identity verification requirements for all new individual company directors and people with significant control (PSCs). There will also be a 12-month transition period for existing individual directors and PSCs to verify their identity as part of the annual confirmation statement filing.

To help prepare for these requirements, from 8 April 2025, individuals can voluntarily verify their identity either directly with Companies House or indirectly through an authorised corporate service provider (ACSP).

Direct identity verification at Companies House

There are three options for direct identity verification with Companies House:

• an app (the GOV.UK One Login ID Check app) – this involves digital facial verification and the submission of a photo of an approved photo ID (eg biometric passport/UK driving licence) and a photo of the individual's face. For people with a biometric passport/UK driving licence, this option is likely to be the easiest way to verify their identity.
• a website (the GOV.UK One Login web channel) – this involves the applicant answering a series of online security questions.
• a face-to-face option (the GOV.UK One Login face-to-face service) – this involves the applicant attending a post office for a face-to-face appointment booked via the GOV.UK website

All three options require applicants to provide certain personal details (eg name, date of birth, email and home address) and evidence to support their application which, depending on the option used, includes a passport, a UK/EU photocard driving licence, a UK residence permit or an EEA national identity photocard. Note, however, that the app and website options are only available for people with certain UK forms of ID or a biometric passport and the face-to-face option is only available to those who can provide a UK home address. Direct verification may not therefore be suitable for some non-UK directors and PSCs.

Indirect verification through an ACSP

People who are unable to use the Companies House options or who may require assistance with the process can verify their identity using an ACSP. ACSPs must be supervised by one of the relevant UK anti-money laundering supervisory bodies (eg lawyers, accountants, company formation agents) and registered as an ACSP with Companies House. Providers can register from 18 March 2025.

To verify with an ACSP, applicants will need to provide the same personal details as are required for direct verification through Companies House. Two forms of evidence may be required to support their application: photographic ID and a form of supporting documentation. Passports without a biometric chip and certain non-UK documents will be accepted as evidence.

Unique identifiers/personal codes

In general, identity verification is a one-off exercise. Once someone is verified, they will obtain a "verified status" account at Companies House and a unique identifier (ie a personal code) for all their roles (whether as a director, a PSC etc) that require verification. However, they will not be required to provide the personal code to Companies House on filings, company incorporations and director appointments etc until autumn 2025.

Failure to verify

Once identity verification becomes mandatory, directors and PSCs who fail verify their identity will commit a criminal offence and/or incur a civil penalty. Companies that are directed by an unverified director will also commit an offence.

 

What action should I take now to prepare for these identity verification changes?

• Draw up a list of existing directors and PSCs who will need to be verified and make them aware that they will need to be ready to verify their identity in due course.
• Consider whether new and existing directors and PSCs should voluntarily verify their identity ahead of the mandatory requirements coming into force. If they do, ensure their unique identifier/personal code is kept safely and is ready to be provided on relevant Companies House filings from autumn 2025.
• Start thinking about putting procedures in place for identity verification. For example, review your procedures for appointing new directors to ensure their identity is verified on or before appointment.

 

Other key measures to come into force

Other company law reforms will be rolled out in stages during 2025 and 2026, including:

Company filings

From spring 2026, ECCTA will restrict the range of individuals who can file documents at Companies House on behalf of a company. This will be limited to an officer or employee of the relevant company (whose identity has been verified) or an ACSP (or its officers or employees).

Directors

It will be an offence for a person to act as a director unless their identity has been verified and their appointment has been notified to Companies House before the statutory deadline. New grounds for disqualification will include persistent failure to comply with identity verification requirements and filing obligations.

ECCTA will also introduce the long-anticipated ban on corporate directors, with powers to make exceptions to the general prohibition, already contained in the Companies Act 2006 (CA 2006).

Company registers

ECCTA will remove the requirement for companies to keep a register of directors, register of directors' residential addresses, register of secretaries and a PSC register. Instead, all relevant information will simply be provided to, and maintained at, Companies House.

Register of members

Companies will still be required to keep their own register of members, but private companies will no longer be able to keep the register at Companies House. Companies will also need to keep standardised information about their members (eg their forename (no initials), surname and service address).

All companies (other than traded companies which are subject to DTR 5) will also be required to provide a one-off list of shareholders in their first confirmation statement after the relevant provision comes into force. For traded companies (which aren't subject to DTR 5), the statement will only include those shareholders holding at least 5% of any class of shares.

 

How should I prepare for these other key measures?

• Consider compiling a list of individuals (in addition to directors) who file documents at Companies House on the company's behalf (eg company secretaries) and make them aware that they may need to verify their identity in due course.
• Start reviewing your procedures for appointing new directors to ensure they avoid committing an offence (ie ensuring their identity is verified and their appointment is notified to Companies House before the statutory deadline).
• Check if there are any corporate directors in office and if they will meet the exceptions to the general prohibition on corporate directors or if they will need to be removed or replaced.
• Ensure all director, secretary and PSC filings are up to date in advance of the abolition of the statutory registers and consider what internal records you want to keep following the abolition.
• Review your existing register of members to determine if any additional information may be required from members to meet the new standardised information requirements and to ensure you will be able to provide the one-off shareholder list. If you're currently keeping your register of members at Companies House, take steps to recreate it and maintain it going forward.

 

Other changes that have already come into force

As a reminder, Companies House introduced the following key changes in 2024:

 

Further guidance

For further guidance on the matters covered in this publication, please get in touch with your usual Corporate contact at DLA Piper.