Companies House approach to enforcement of identity verification compliance

From 18 November 2025, identity verification (IDV) of directors and persons with significant control (PSCs) has become a mandatory obligation. Companies House has published guidance explaining how it will approach non-compliance and enforcement action that they’ll take.

IDV applies to all directors and PSCs of entities registered with Companies House. Verification can be completed directly through GOV.UK One Login or via an Authorised Corporate Service Provider (ACSP). Once verified, individuals receive a unique code which is used to link them to their roles across all Companies House registered entities.

The mandatory date of 18 November is however not a hard deadline for IDV to have been carried out, but the commencement of a roll out period. Existing directors and PSCs have a twelve-month transition period to complete verification, while new appointments must verify before they can act. For existing directors, their IDV must be completed before the entity’s next confirmation statement is due and can be filed. 

For PSCs, they must have carried out IDV by the next anniversary of the month of their birth. The registrar has discretion to extend the identity verification due date for a PSC by up to 14 days, and where this is extended the PSC remains compliant. If the PSC doesn’t submit their identity verification statement before the extended due date, they’ll be in breach of the law.

This phased approach for directors and PSCs is intended to give businesses time to adapt, but responsibility for compliance rests firmly with individuals and companies.

Companies House approach to enforcement 

The approach to enforcement will be through 4 broad categories:

• Informing people of their obligations
• Nudging and guiding
• Dealing with non-compliance
• Addressing fraud and criminal activity

Companies House has made clear that its enforcement strategy will be proportionate, but it won’t hesitate to act where necessary. 

During the initial transition period, the emphasis will be on education and engagement. Reminders and guidance will form the central activity to encourage early compliance with clear messaging about what individuals must do, how and by when.

Companies will be emailed directly before filing their annual confirmation statement to tell them they must provide identity verification statements for each of their directors by their filing deadline. Other channels of communications and activities will also be used to support compliance. This includes for example, webinars and online guidance.

However, enforcement will escalate where obligations are ignored. The first practical consequence of failing to verify is operational: Individuals who haven’t completed verification will be unable to file statutory documents, such as confirmation statements, or incorporate new companies. This restriction alone could cause disruption and cause directors and companies to be non-compliant and vulnerable to penalties for failure to comply with legal filing requirements.

If non-compliance persists, Companies House can impose financial penalties. These civil sanctions are designed to encourage compliance without resorting immediately to criminal proceedings.

Where there is evidence of deliberate evasion or fraudulent activity, the enforcement action will be escalated further. Criminal prosecution under the Companies Act 2006 is a possibility, and those found guilty could face significant fines or imprisonment. Prosecution is also more likely in serious cases, which is considered to be where a person or company has committed 3 or more offences over a 5-year period, where fraudulent identity documentation has been used or there’s evidence of criminal activity.

Even where cases aren’t selected for prosecution, directors and equivalents may still be committing an offence under 167M of the Companies Act 2006 for continuing to act without identity verification, with the company also in breach for failing to rectify this. In these instances, Companies House will write to the company outlining these offences and the need to comply with identity verification. They’ll also be informed that they must rectify the position for directors that aren’t complying or advise that the company is no longer needed. Continuing to act without identity verification may result in a referral to The Insolvency Service.

Where there is evidence of aggravated, fraudulent or criminal offences, Companies House may share information with law enforcement agencies to support investigations into economic crime.

The guidance stresses that enforcement will be risk-based. Companies House will prioritise cases where there’s a clear threat to the integrity of the register or evidence of criminal intent. However, even inadvertent non-compliance is likely to attract consequences. 

Further information

You can read the full guidance which is published on gov.uk