Companies House ID Verification: The 2026 Board Checklist
Companies House identity verification is now mandatory for every UK director and person with significant control (PSC), under powers created by the Economic Crime and Corporate Transparency Act 2023 (ECCTA).
The transition period runs to 18 November 2026, and it is not a soft deadline: an unverified director blocks the company’s next confirmation statement, and an unfiled confirmation statement is itself a criminal offence under the Companies Act 2006. For boards used to treating Companies House filings as an administrative afterthought, that chain of consequences deserves board-level attention now, not in October.
What is Companies House ID verification, and who must comply?
Every director, and every PSC, of a UK company must verify their identity with Companies House, whether they are UK-based or overseas. Verification can be completed directly via GOV.UK One Login, or through an Authorised Corporate Service Provider (ACSP) such as a solicitor or accountant already conducting the company’s filings. Once verified, an individual receives a personal code that must be quoted on the company’s next confirmation statement.
New directors appointed from 18 November 2025 must verify before appointment can be registered. Existing directors and PSCs sit inside a 12-month transition window that closes on 18 November 2026, but in practice the operative deadline for most companies is earlier: verification must be complete before the next confirmation statement is due, and confirmation statement dates are staggered across the year based on incorporation anniversary.
Executive Action:
- Pull a list of every director and PSC across group entities, with each individual’s confirmation statement trigger date
- Confirm which route each individual will use — GOV.UK One Login (self-service) or ACSP (via existing legal or accountancy advisers)
- Assign a named owner (typically company secretary or general counsel) to track completion against filing deadlines, not the November backstop
What happens if a director misses the 18 November 2026 deadline?
Companies House will not accept a confirmation statement if any listed director or PSC’s personal ID code is missing. A rejected or late confirmation statement is a criminal offence under the Companies Act 2006, and persistent failure can lead to the company being struck off the register.
According to Companies House, an estimated 6 to 7 million directors and PSCs across the UK company register must complete identity verification within the transition period — a volume that has already produced delays at peak filing periods and is expected to worsen as the deadline approaches. According to GOV.UK guidance on the regime, non-compliance after the transition period closes is a criminal offence carrying fines of up to £5,000 per individual, alongside potential director disqualification.
Companies House has confirmed it will not prosecute for non-verification during the transition period itself — but the practical consequence, a blocked confirmation statement, lands immediately and does not wait for enforcement powers to activate.
Executive Action:
- Treat “confirmation statement due date minus six weeks” as the internal deadline, not 18 November 2026
- Escalate any director or PSC who has not verified within 30 days of a reminder — do not rely on self-service uptake
- Brief the board that a filing failure is a Companies Act 2006 offence with personal exposure, not a back-office administrative lapse
How should boards get ahead of the confirmation statement trap?
The risk is concentrated wherever accountability is diffuse: multi-entity groups, portfolio companies with rotating non-executive directors, and PSCs who are individuals rather than corporate entities and may not routinely engage with company administration. Boards with overseas directors face an added step, since non-UK residents must still verify via GOV.UK One Login or a UK-based ACSP.
Audit and risk committees are well placed to own this because it sits at the intersection of regulatory compliance and personal director liability — the same territory as Provision 29 controls reporting under the UK Corporate Governance Code. A short standing item — verification status against each entity’s next confirmation statement date — closes the gap before it becomes a filing crisis.
Executive Action:
- Add ID verification status to the audit or risk committee’s standing agenda until every director and PSC in the group is confirmed
- For groups with multiple UK entities, verify once (a personal code is portable across appointments) but map coverage entity-by-entity
- Flag overseas directors and individual PSCs as the highest-risk cohort for missed deadlines
What should company secretaries and general counsel do now?
With under five months to the transition deadline, the practical task is triage, not policy design. Identify which entities’ confirmation statements fall due before 18 November 2026, confirm verification status for every named individual against those dates, and close gaps through the faster of the two routes — ACSP verification, where an adviser is already engaged, tends to complete faster than individual GOV.UK One Login sign-up during peak periods.
INFORMD’s governance risk assessment tools can help boards benchmark where verification and broader director-duty obligations currently stand, and the capital and technology strategy review templates offer a structure for documenting the control owner and completion date per entity — evidence that matters if a filing is ever challenged. Questions on scoping this for your group structure can go to our team via /contact/.
Executive Action:
- Set a group-wide verification completion target of 30 September 2026, six weeks ahead of the hard deadline
- Document the verification route and completion date per individual as part of the company’s internal controls record
- Brief the board in writing that filing failure carries a personal, not just corporate, compliance risk
Every director and person with significant control (PSC) of a UK company, whether UK-based or overseas. New appointees must verify from 18 November 2025; existing directors and PSCs have until 18 November 2026, or their next confirmation statement, whichever comes first.
The transition period runs to 18 November 2026. In practice, verification must be complete before the company’s next confirmation statement is filed, so the real deadline for most directors falls earlier in the year.
Companies House will reject the confirmation statement. An unfiled or rejected confirmation statement is a criminal offence under the Companies Act 2006 and can ultimately lead to the company being struck off the register.
Directly via GOV.UK One Login, a free self-service process, or through an Authorised Corporate Service Provider (ACSP) such as a solicitor or accountant. Verification produces a personal code used on future filings.
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