New identification requirements coming from Companies House

19 February 2025

Last updated: 2 December 2025

David Menzies
Director of Practice, ICAS

A significant change is coming for directors, officers and persons with significant control (PSCs) of entities which are required to register with Companies House.

Identity verification (IDV) is a key measure brought in by the Economic Crime and Corporate Transparency Act 2023 (ECCTA 2023). This means that Companies House will require anyone setting up, running, owning or controlling a company, limited liability partnership or limited partnership (entities) in the UK to verify their identity to prove they are who they claim to be – irrespective of their nationality or where they are resident.

The requirements are part of a wider deterrent aimed at preventing false and misleading information being used and using entities as part of a legitimate front for illegal economic crime activities.

Who will require to have their identities verified?

The IDV requirements will apply to entities which are registered with the Register of Companies. For companies, this will include all types of limited companies, including companies limited by guarantee which are often used by charities and other not-for-profit organisations.

The IDV requirements will apply to all directors, PSCs and those acting on behalf of entities.

IDV will require to be undertaken for all existing and all new individuals associated with entities. Companies House have indicated that nearly 7.5 million individuals are connected with existing entities and will be impacted by the requirement to undertake IDV.

When will the new requirements come into effect?

The new requirements will be phased.

From 8 April 2025, individuals will be able to verify their identity on a voluntary basis. Although a date for mandatory IDV has not yet been confirmed, the Economic crime transition plan for Companies House indicates that this is expected in the autumn of 2025 for new incorporations. There will be a 12-month transition timescale for existing individuals who will be required to provide IDV by when their confirmation statement is due.

How will identities be verified?

There are two routes to have IDV carried out.

Directly with Companies House

Individuals will be able to do this through GOV.UK One Login. There are three ways to prove identity with GOV.UK One Login: Either using the GOV.UK One Login app; by answering security questions online; or taking documents to a Post Office. The method most likely to be convenient will depend on access to a mobile phone with a camera, if the individual has photo ID and what type of photo ID it is.

With the GOV.UK ID One Login app, documents such as a UK photocard driving licence, UK passport, a non-UK passport with a biometric chip, a UK biometric residence permit, UK biometric residence card, or UK Frontier Worker permit can be used.

The security questions that will have to be answered online cover things like the individual’s mobile phone contract, and any bank accounts, credit cards, loans or mortgages that they may have. In addition, details will be required from either a UK passport, a UK photocard driving licence or a current account with a UK bank or building society.

If using the Post Office, the individual will need to enter details from their photo ID on GOV.UK and then go to a Post Office that offers ‘in branch verification’ services where they’ll scan the photo ID and take a photo of the individual. Only a UK passport, non-UK passport, UK photocard driving licence, European Union (EU) photocard driving licence, national identity photocard from an EU country, Norway, Iceland or Liechtenstein will be accepted as photo ID.

Authorised Corporate Services Provider (ACSP)

The other alternative is to use an ACSP to carry out the IDV. ACSPs are individuals or organisations such as company formation agents, solicitors, accountants, chartered secretaries and governance professionals who have registered as ACSP’s with Companies House. ACSPs will also be known as Companies House authorised agents. IDVs carried out by ACSPs must meet the same level of assurance as those who verify directly with Companies House.

What will happen after the IDV has been carried out?

Every individual who carries out an IDV will be allocated a unique identification number by Companies House. That unique ID number will be able to be used to be associated with appointments across any number of entities that an individual is associated with.

Currently, while Companies House try and identify appointments common to an individual, deliberate (or otherwise) inconsistencies in information provided make this impossible to achieve with certainty. Going forward, it should be possible to ensure that all appointments relating to an individual are correctly linked to the same individual’s record.

Action required

This change probably represents the biggest impact on Companies House and individuals associated with entities as part of the package of measures being introduced through ECCTA 2023.

While Companies House has a communication plan in place to explain and raise awareness among those impacted, for many entities they rely on their professional advisors to give them advice and keep them updated.

Accountancy firms should:

Consider whether IDV is required by your client base. Identify who will be impacted and who will not be impacted.

Consider how they are going to advise clients of the change and make them aware that they will have to undertake IDV.

Consider how they will roll out the communication (and possibly also undertake the IDV or ensure that it has been undertaken). This could be done on a rolling basis (eg as annual accounts are done), by segmentation (eg by engagement partner or a certain number of clients at a time), or in a single exercise.

Decide whether they will provide IDV services or whether they will advise individuals to use the Companies House IDV service. It’s worth noting that providing IDV services will result in the firm becoming a Trust and Company Services Provider (TCSP) under anti-money laundering (AML) regulations for which firms are required to be registered. If firms are unsure whether they are registered as a TCSP they should contact their AML supervisor. For firms where ICAS is their AML supervisor they should contact Regulatory Authorisations.

If planning to provide IDV services:

Register as an ACSP with Companies House as soon as possible once the registration service opens. (see article on What you need to know about becoming an Authorised Corporate Service Provider). Note that ACSP and TCSP is different.