Identity Verification A New UK Legal Requirement Under ECCTA

Under the Economic Crime and Corporate Transparency Act 2023 (ECCTA), UK directors, LLP members, persons with significant control and people filing information at Companies House will be legally required to undergo identity verification (IDV), following which they will be issued with a unique identifier (i.e., a personal code).

Whose Identity Needs to Be Verified?

Directors (mandatory from 18 November 2025 for individual directors)

A new director being appointed to existing UK companies or on new UK company incorporations will need to have their identity verified before their appointment is notified to Companies House.
The obligation is on both the individual (to not act as a director unless their identity has been verified) and the company (to ensure an individual does not act as director unless their identity has been verified). Breach will constitute an offence under the Companies Act 2006, although failure to undergo IDV will not affect the validity of actions undertaken by such director.
Existing directors of UK companies will need to complete IDV by the time of the next confirmation statement within the 12-month transition period starting 18 November 2025. Companies with confirmation statements due this year are well-advised to seek unique identifiers from their directors in advance of the transition period to avoid a last-minute rush.
IDV for corporate directors will begin at a later date yet to be confirmed.

PSCs and RLEs (mandatory from 18 November 2025 for individual PSCs)

Registrable persons with significant control (PSCs) and relevant officers of registrable relevant legal entities (RLEs) will need to verify their identity and confirm verification with Companies House either at company incorporation or when notifying Companies House that a person has become a registrable PSC or RLE.
From 18 November 2025, a new individual PSC will need to supply their unique identifier on incorporation or within 14 days of their appointment being notified to Companies House.
Existing PSCs who are also directors of the company will have 14 days from the company's confirmation statement date to confirm their identity as a PSC. Existing PSCs who are not directors of the company must provide a verification statement and their unique identifier within 14 days of the first day of their birth month.
For relevant officers of RLEs, timings are yet to be confirmed.
The requirements for PSCs and RLEs apply to all those subject to the PSC regime, including certain UK companies, LLPs and Scottish limited partnerships.

LLP members (mandatory from 18 November 2025, pending related secondary legislation coming into effect)

All new and existing members of UK LLPs will need to verify their identity. Timings for individual LLP members are expected to be similar to the requirements for company directors (and will be confirmed for corporate LLP members).
Existing UK LLP members will need to have their identity verified by the LLP's next confirmation statement date within the 12-month transition period starting 18 November 2025.
Where a member is a corporate entity, one of its individual directors (or equivalents) will need to have their identity verified.

Individuals filing information at Companies House (mandatory from spring 2026)

An individual filing information at Companies House on behalf of a company will only be able to do so if they are an officer or employee of that company (note this does not currently extend to officers/employees of another group company) and have had their identity verified or they are an authorised corporate service provider (ACSP) or an officer/employee of an ACSP.

Limited partnerships (expected to apply from spring 2026)

A general partner which is a legal entity (including LLPs and Scottish limited partnerships) will need to specify an individual managing officer to act as its "registered officer" and such registered officer must have their identity verified. This is anticipated to apply no earlier than spring 2026 (with the other reforms to UK limited partnerships), with a six month transitional period for existing limited partnerships.

Further Notes

Failure to meet the IDV requirements is an offence and can result in a fine. There are limited exemptions to the above for the purposes of national security or the prevention of serious crime. Each individual will (in most cases) only need to verify their identity once. Voluntary IDV commenced on 8 April 2025, meaning that all individuals requiring IDV may apply now.

How Do You Verify Your Identity?

There are a number of options available:

Direct verification atCompanies House, using the GOV.UK One Login app or web service or in-person at a post office (which is free).
Verification by an ACSP, remotely or in-person depending on the provider. There are a number of ACSP providers offering IDV services.

The documents required will depend on the selected option. A home address and an email address must also be provided.

For UK-based individuals, the following options are available:

GOV.UK One Login app (with a UK biometric passport, UK photocard driving licence, UK biometric residence permit/card or UK frontier worker permit).
GOV.UK One Login web service (with a UK passport, UK photocard driving licence, or UK bank account supported by a UK national insurance number).
GOV.UK One Login face-to-face service, at a post office (with a UK passport, UK photocard driving licence, or UK biometric residence permit, plus UK home address).
An ACSP (with document requirements depending on the ACSP).

For non-UK based individuals, the following options are available:

GOV.UK One Login app (with a biometric passport).
GOV.UK One Login face-to-face service at a post office (with a biometric passport, a non-biometric passport from selected countries only, an EU photocard driving licence, or biometric photocard from an EEA country).
An ACSP (with document requirements depending on the ACSP).

Non-UK based individuals with a non-biometric passport will likely need to use an ACSP.

Whichever option is used, once identity is successfully verified, the individual will receive a unique identifier, also known as a Companies House personal code. Only one unique identifier is required per person, regardless of how many directorships or LLP memberships that they hold. If the IDV is carried out by an ACSP, the ACSP will file a verification statement at Companies House and the individual will be treated as having their identity verified on the date that the statement is filed.

Next Steps for IDV?

Check who within your organisation requires IDV (e.g., existing directors, any directors anticipated to be appointed, company secretaries who are responsible for filing documents at Companies House, PSCs and RLEs).
Check that each individual requiring IDV holds up-to-date documentation. Any individuals without suitable documentation may first need to apply for this.
Check when your confirmation statements are due, as IDV requirements will need to be met by the date on which the next confirmation statement is due (even if that falls before the end of the 12-month transition period).
Check dates of birth for PSCs who are not directors, as they will need to confirm IDV within 14 days of the first day of their birth month.
Encourage individuals requiring IDV to have their identity verified now, using one of the listed options to avoid a last-minute rush when it becomes mandatory.

What Else Should You Know About ECCTA?

Other changes under ECCTA include:

The introduction of a new failure to prevent fraud offence (to learn more read: "The UK's Failure to Prevent Fraud Offence: Private Fund Managers, Portfolio Companies, and Placement Agents", published July 2025), effective since 1 September 2025.
The widening of corporate criminal liability for economic crimes.
The introduction of a new false statement offence, for delivering to the registrar a document/statement that is misleading, false or deceptive in a material particular, without reasonable excuse (this being a higher bar than was previously the case).
Changes to accounts filing options for micro-entities and small companies.
New grounds for director disqualification, including persistent breaches of filing obligations and IDV requirements (anticipated to apply from 18 November 2025).
The removal of the requirement for companies to keep registers of directors, directors' residential addresses, secretaries and PSCs from 18 November 2025 - instead, this information is to be maintained at Companies House. Companies will still be required to keep a register of members (and no longer on the Companies House central register).

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.