Identity verification and Authorised Corporate Service Providers

Perhaps the most significant of the Act’s reforms is the introduction of compulsory identity verification procedures for all new and existing company directors, persons with significant control (PSCs) and agents who file information at Companies House. The main aim behind the new verification process is to prevent fraudulent or fictitious appointments of directors or beneficial owners from being recorded at Companies House.

Identity verification for directors

All directors, both new and existing, will have to undergo identity verification, and the Act specifically prohibits directors (including shadow directors) from acting unless their identity has been verified. The Act also places an obligation on companies to ensure that individuals do not act as directors unless their identity is verified.

In practice, this means that until an individual’s identity is verified, a director should not take any actions on behalf of the company in their capacity as a director. If a person fails to verify their identity and continues to act as a director, they are committing an offence which is punishable by a fine. However, the director’s appointment and the actions they may have undertaken as a director will still be valid.

A company will also commit a criminal offence if it allows a director to act while unverified.

Timing

As set out in the Government’s outline transition plan (the Transition Plan), individuals may voluntarily verify their identity from 8 April 2025. Mandatory verification for new directors is scheduled to be introduced by autumn 2025.

Once mandatory verification is in force, it will not be possible to incorporate a new company without the proposed officers of the new company having been verified, and their verified status will have to be confirmed in the Companies House application form. 

Post-incorporation, new directors will have to verify before their appointment is notified to Companies House (which must happen within 14 days of appointment). 

For existing directors, there will be a 12-month transition period (starting in autumn 2025) in which they will be given time to comply with the new verification requirements. This identity verification will happen as part of a company’s annual confirmation statement filing, meaning that all existing directors will be required to file evidence of their identity being verified at the same time as filing the company’s first confirmation statement during that period.

Identity verification for PSCs

All new and existing PSCs will also need to verify their identity and maintain that verified status as long as they are registered at Companies House. Where the registrable PSC is a legal entity – a relevant legal entity (RLE) – the entity will have to nominate a managing officer who is an individual and whose identity has been verified.

New PSCs and RLEs will be able to be registered without having had their identities verified in advance. However, any new PSC must become verified and confirm that status to the registrar within 14 days of receipt of a notice from the registrar. RLEs will have 28 days from receipt of the notice to comply.

There will be a transition period during which existing PSCs and RLEs will have time to verify their identity. Companies that do not comply by the end of that period may face criminal sanctions or civil penalties. 

As referred to above, individuals are able to voluntarily verify their identity from 8 April 2025. Mandatory verification for new PSCs and RLEs will be introduced by autumn 2025, and the 12-month transition phase for existing PSCs and RLEs will begin at the same time. 

How will identity verification work?

Companies House has published new guidance on the verification process.

There will be two routes for verifying an individual’s identity:

• direct verification with Companies House; or 
• verification by a third party provider – an authorised corporate service provider (ACSP) (see below).

From 8 April 2025, individuals will be able to verify directly with Companies House, either online or in person (at a post office). Both options require a Gov.UK One Login and are free of charge. 

Individuals should be able to verify online with Companies House if they have one of the following types of photo ID:

• biometric passport from any country;
• UK photo driving licence (full or provisional);
• UK biometric residence permit;
• UK biometric residence card; or
• UK Frontier Worker permit.

Once signed in, GOV.UK One Login will guide the user to verify their identity using either the GOV.UK ID Check app (which will require access to a phone with a working camera to complete a facial scan), or by answering security questions via a web browser. Anyone who does not have any of these types of ID but who lives in the UK, may still be able to verify with bank or building society details instead. The “Verify your identity for Companies House” service will have to be used to establish whether it is possible to verify in this way. As well as providing identity documentation, individuals will need to provide a valid email address and a current residential address.

If an individual is not able to verify online and lives in the UK, it may be possible to verify in person at a post office that offers “in branch verification”. Specified photo ID will still be required and this will be scanned by the post office and a photo of the individual taken. 

Although it is envisaged that most individuals will be able to verify directly with Companies House via the Gov.UK One Login service, there will be some restrictions, particularly in the case of non-UK or non-EU nationals who do not have biometric identification. If individuals are unable to satisfy the documentation requirements for direct verification, they will need to engage an ACSP to verify their identity.

Verified individuals will be allocated a unique identification number (UIN) and each person may have one UIN only. The registrar will be able to use UINs to link the records of verified individuals holding multiple roles in different organisations.

Authorised Corporate Service Providers

As stated above, individuals might choose to (or might be required to) use an ACSP to verify their identity rather than using the facility provided by Companies House. The identity verification checks undertaken by ACSPs will achieve the same level of assurance as those undertaken by Companies House.

To obtain ACSP status, intermediaries and agents will have to be authorised by Companies House and be supervised within the UK by one of the relevant anti-money laundering (AML) supervisory bodies. The application process should be completed by someone senior within the relevant organisation, such as a director, and that senior person will need to have their own identity verified as part of the process. 

Once registered, the ACSP will be provided with a digital account and a UIN which will allow them to complete identity verification checks and to file information at Companies House for their clients (see below). If an ACSP conducts identity verification, it will need to keep records for seven years. 

The person registering the business as an ACSP will be able to add other people who work for the business to the ACSP account once it has been registered and approved. These employees will not be subject to identity verification but will be allowed to carry out identity checks and file documentation for clients on behalf of the ACSP.

Individuals and organisations were able to register as an ACSP from 18 March 2025.

Filing information at Companies House

Once the relevant provisions are in force, only ACSPs and verified individuals will be able to file information at Companies House on behalf of a company or other registered entity. This is a significant change from the current situation where anyone is able to deliver documents to Companies House. The Transition Plan anticipates that this reform will be effective by spring 2026.

Many companies currently use third parties, such as accountants, to file information on their behalf. These third parties will need to register as an ACSP in order to continue doing this. By requiring all third party agents to register their business and verify their identity, the Government will be able to confidently identify who is filing on the register and acting on behalf of companies. It will also help in the identification of agents who may not be acting with a lawful purpose, enabling the Government to take action more quickly. 

Resources

• Government Factsheet: Identity verification and authorised corporate service providers
• The Economic Crime and Corporate Transparency Act 2023
• The Registrar (Identity Verification and Authorised Corporate Service Providers) Regulations 2025
• The Registrar’s (Identity Verification by the Registrar) Rules 2025
• The Registrar’s (Identity Verification by Authorised Corporate Service Providers) Rules 2025
• The Registrar’s (Requirements Applicable to Applications to Become an Authorised Corporate Service Provider) Rules 2025
• Companies House blog (January 2025)
• Economic Crime and Corporate Transparency Act: outline transition plan for Companies House
• The Unique Identifiers (Application of Company Law) Regulations 2025
• Companies House guidance: Applying to register as a Companies House authorised agent
• Companies House guidance: Being an Authorised Corporate Service Provider
• Companies House guidance: How to meet Companies House identity verification standard
• Companies House guidance: Verifying your identity for Companies House