

The Economic Crime and Corporate Transparency Act 2023 (ECCTA) has introduced a new identity verification (IDV) regime which requires individuals holding certain positions within organisations and/or making filings with Companies House to have their identities verified.
Voluntary IDV started on 8 April 2025 and the legal requirement to do so will come into force in autumn 2025.
Those who will need to verify their identity include:
New directors, PSCs, and members of LLPs: from autumn 2025 (date yet to be announced), these persons will need to have their identity verified as part of the relevant organisation’s incorporation or their appointment to an existing organisation.
Existing directors, PSCs, and members of LLPs: from the same autumn date as above, these persons will need to have their identity verified before the relevant organisation submits its annual confirmation statement. Therefore, if an organisation’s confirmation statement is due before the autumn 2025 date, all relevant persons will not need to verify their identities until the 2026 confirmation statement is due. But if an organisation’s confirmation statement is due after the autumn 2025 date (even if by just one week), all relevant persons will need to verify their identities before that date. Companies House has indicated that directors of overseas companies and general partners of limited partnerships will also need to start having their identities verified from autumn.
Other listed persons: Companies House currently anticipates that the IDV requirement for anyone who files documents at Companies House will come into force in Spring 2026.
There are three ways that individuals can verify their identity – these are:
In addition, every individual having their identity verified must have a valid email and residential address.
All registrable PSCs who are legal entities, i.e. RLEs, will be required to nominate a “relevant officer” who is an individual and whose identity has been verified in the same way as described above.
Corporate directors are expected to be abolished under ECCTA in the near future. However, once in force, there will be an exception to this rule whereby a corporate entity registered in the UK will be able to be a director of a UK company provided that:
Once an individual or an organisation has had their identity verified, Companies House will issue a personal code as evidence of their IDV. From autumn 2025, individuals will be required by Companies House to submit this personal code every time that they, for example:
IDV is expected to be required by a single individual on one occasion only.
However, certain situations may require IDV to be repeated, for example, where a person changes their name following marriage or divorce.
A director will commit a criminal offence (as will the relevant organisation and, in certain cases, the other officers) where they:
Directors who commit this offence will be at risk of a fine and, where appropriate, may also be disqualified as a director. The incorporation of a new company may be rejected by Companies House and, in serious cases, criminal proceedings may be initiated. Individuals will also likely be prohibited from submitting future filings with Companies House if they have not complied with the requirements.
A PSC will be committing a criminal offence if they do not comply and are at risk of a fine.
It has not yet been confirmed whether such offences will also apply to LLP members and other personnel who are required to complete IDV but it should be assumed that they will.
Organisations should review their group’s structure and identify all the persons within each organisation (i.e. their PSCs, directors, members, etc.) that will be affected by the new IDV regime. They should also pinpoint the expected compliance deadlines (which will usually be the date of filing of the next confirmation statement following autumn 2025).
It is also important to consider whether any of the group’s companies or partnerships are RLEs and to decide who the “relevant officer” is for each.
Organisations should consider ensuring that all of the relevant individuals verify their identities voluntarily now or at least starting the process to ensure that future compliance deadlines are not missed.
For further advice on IDV offences and whether your organisation could be affected, please contact HFW.
Michael Popp, Trainee Solicitor, assisted in the preparation of this briefing.