The requirement was introduced under the Economic Crime and Corporate Transparency Act 2023 and announced by Companies House, the UK authority responsible for the company register.
The measure is intended to enhance the transparency, accuracy and reliability of the UK company register, improve the quality of corporate information and prevent the misuse of corporate structures.
Who is required to verify their identity
The identity verification requirement applies to individuals holding certain roles within UK companies, including:
- Company directors;
- Members of LLPs (Limited Liability Partnerships);
- Persons with Significant Control (PSCs);
- Others who file documents or act on behalf of a company.
Identity verification methods
There are two ways to complete the verification process:
- Self-Verification (Self-IDV): Individuals may complete the process independently via GOV.UK One Login, using the GOV.UK ID Check app to scan an identity document and complete a facial recognition check.
- Verification through an authorised intermediary (ACSP): Alternatively, identity verification may be carried out by an Authorised Corporate Service Provider (ACSP), an intermediary registered with Companies House and subject to anti-money laundering supervision.
Personal ID Code: differences between Directors and PSCs
Following recent clarification from Companies House, the use of the Personal ID Code differs between directors and People with significant control (PSC).
- Directors: must complete identity verification and obtain a Personal ID Code.
The linking of the code to the directorship is carried out by the company when filing the confirmation statement. - People with Significant Control (PSCs): PSCs are required to personally link their Personal ID Code to their role within the first 14 days of their birth month. If the PSC is also a director, this requirement must be completed during the 14-day period available for filing the Confirmation Statement.
Overseas entities
For overseas entities registered on the Register of Overseas Entities (ROE), identity verification is required only if the entity opens a UK establishment (such as a branch, office or other permanent presence in the UK). The ownership of UK property, even where the property is rented out, does not constitute the opening of a UK establishment and does not trigger any identity verification requirement.
Consequences of non-compliance
Failure to complete identity verification may result in sanctions and operational restrictions.
In particular, unverified individuals will not be recognised as validly appointed by Companies House and may face difficulties filing company documents, as well as potential civil or criminal penalties.
Giacomo Francioni
Alice Pietri – Trust and Wealth
