The Economic Crime and Corporate Transparency Act 2023 ("ECCTA 2023") introduces a new requirement for various categories of people (including directors, persons with significant control ("PSCs") and those filing documents at Companies House) to have their identity verified. The aim is to deter companies being used for illegal purposes, reduce fraud and improve transparency, trust and accuracy in information held by Companies House.
In its outline transition plan (see here) Companies House anticipates that by autumn 2025 identity verification will be compulsory in relation to new company incorporations and appointments of new directors and PSCs. At the same time, a 12 month transition phase will begin during which all existing directors and PSCs will be required to verify their identity as part of the annual confirmation statement filing. The requirement for people filing information at Companies House to have their identity verified is expected to be compulsory by spring 2026.
Once an individual has their identity verified they will receive a unique identifier number. This number will eventually be required in a number of situations e.g. if the person is appointed as a director or becomes a PSC. Directors and PSCs will also be required to use the number to connect their verified identity to Companies House records.
Although it was originally anticipated that individuals would be able to voluntarily verify their identity from the end of March, this has been pushed back to 8 April 2025.
Individuals will be able to verify their identity in one of two ways:
· Directly with Companies House using GOV.UK One Login
We expect this to be the most commonly used means of identity verification as it should be the most convenient and is free of charge.
GOV.UK One Login allows a person's identity to be checked using:
o the GOV.UK ID Check app (this requires a smart phone and working camera) (see here for guidance on using the app);
o the GOV.UK One Login web service; or
o the GOV.UK One Login face to face service (this requires the applicant to attend a Post Office).
In each case applicants will need access to the internet and will be asked to provide personal information including an email address and their home address.
Each application must be supported by evidence such as a passport, photocard driving licence or details of a UK bank account supported by a National Insurance number.
Further information about identity verification can be found in the recent Companies House guidance (see here). Further information on the GOV.UK One Login can be found here and the Registrars' (Identity Verification by the Registrar) Rules 2025 (which detail the evidence that will be required) can be found here.
· Through an Authorised Corporate Service Provider ("ACSP")
ACSPs are intermediaries such as legal advisers and accountants who are registered with a UK supervisory body for anti-money laundering purposes and also have registered with Companies House as an ACSP.
Registration as an ACSP is necessary to provide the identity verification service. In addition, all intermediaries who wish to make filings at Companies House on behalf of others will have to register as ACSPs by spring 2026.
ACSPs are likely to charge a fee for verifying a person's identity.
It has been possible to register as an ACSP since 18 March 2025. However, it is still too early to tell how many intermediaries will offer an identity verification service due, in large part, to concerns about cost effectiveness in the light of the requirements and the potential risks involved.
It is important to note that most existing directors and PSCs will not be required to have their identity verified until, at the earliest, autumn 2025. While early voluntary identity verification is a good idea, there is, at present, no immediate rush and there may be some merit in waiting at least a few weeks after 8 April to allow any teething problems with the new systems to be resolved.
If you require any further information, or specific advice, please contact our expert team.
