Identity verification at UK Companies House and the company-by-company deadlines to 17 November 2026

What the Economic Crime and Corporate Transparency Act built

The Economic Crime and Corporate Transparency Act 2023 inserted into the Companies Act 2006 a requirement that individuals who run or control UK companies verify their identity with the registrar. Section 1110A defines when an individual's identity is verified: by the registrar under regulations made under section 1110B, or by a verification statement from an authorised corporate service provider within section 1098A. The regulations are the Registrar (Identity Verification and Authorised Corporate Service Providers) Regulations 2025, SI 2025/50, and under regulation 23 the registrar allocates each verified individual a unique identifier, which Companies House calls the personal code. Authorised corporate service providers have been able to register since 18 March 2025 under SI 2025/349, and verification opened on a voluntary basis on 8 April 2025.

The operative prohibition is section 167M. An individual may not act as a director of a company unless the individual's identity is verified, or an exemption applies; the company must not allow an unverified individual to act; and both the individual and the company, with every officer in default, commit an offence. Section 167M(6) preserves the validity of what the director has done, so a board decision taken by an unverified director is not void, but the individual and the company are exposed to the offence, and Companies House says it may annotate the register. A parallel regime applies to persons with significant control under sections 790LM, 790LN and 790LQ: the duty to deliver a statement that the PSC's identity is verified rests on the PSC, although the company's notice of a new PSC may include it (section 790LB(1)), and the equivalent provisions for corporate PSCs are not yet in force. The exemptions are narrow: section 1110C allows the Secretary of State, by written notice, to disapply the requirement where satisfied that this is necessary in the interests of national security or for preventing or detecting serious crime, and the Act contains no exemption for directors who live abroad.

The transitional period, and why it is not one deadline

The commencement instrument is the Economic Crime and Corporate Transparency Act 2023 (Commencement No. 6 and Transitional Provisions) Regulations 2025, SI 2025/1118, made on 22 October 2025, which brought section 167M into force on 18 November 2025 and disapplied it for directors appointed before that date during a transitional period of twelve months beginning with that day; existing PSCs were given appointed days under regulation 5. From 18 November 2025 the notice of a new director's appointment must state that the individual's identity is verified (section 167G(3)(c)), and for a new PSC either the company's notice includes that statement or the PSC must deliver it within fourteen days of a direction from the registrar (section 790LM), which Companies House's guidance (updated 30 July 2026) describes as providing the personal code within fourteen days of being added to the register. For existing office-holders the Regulations work company by company.

Regulation 4 deals with existing directors. During the transitional period, an individual who became a director before 18 November 2025 is relieved from section 167M until the company delivers its next confirmation statement, which must include a statement that each director's identity is verified; the relief ends the day after the statement is delivered or, if the company does not deliver it, the day after the end of the fourteen-day period within which the statement was due. A company that had not delivered a statement whose delivery period ended before 18 November 2025 had relief only until the end of 2 December 2025 (regulation 4(7) and (8)). Companies House's guidance on confirmation statements (updated 21 April 2026) states that it will not accept a company's confirmation statement until all directors have verified, which converts the statutory relief into a hard filing dependency: a company that cannot deliver its confirmation statement because one overseas director has not verified is late on the statement as well.

Regulation 5 deals with existing PSCs. An individual who was a registrable PSC on 18 November 2025 and is not also a director of the company must deliver a statement that his or her identity is verified (section 790LN), in practice by providing the personal code, within a fourteen-day window beginning on the first day of his or her birth month, running from December 2025 to November 2026. The window governs the statement; the verification itself can be completed earlier. A PSC who is also a director has a separate fourteen-day window: it begins on the day after the end of the company's first review period ending between 18 November 2025 and 17 November 2026 (regulation 5(3) and (4)), the personal code is provided for each role separately, and a director-PSC whose particulars are protected from public inspection follows the birth-month table instead. The twelve-month period ends on 17 November 2026. On our reading of regulation 4(6), the latest the relief for directors can end is 2 December 2026, for a company whose review period ends on 17 November 2026 and whose statement is therefore due by 1 December; that arises only where its previous statement was made up to 17 November 2025 and delivered before 18 November 2025. Companies House's guidance does not state that date, and for most companies the deadline falls well before 17 November 2026.

Directors outside the United Kingdom

Groups whose UK subsidiaries are run by directors outside the United Kingdom, for example in Zurich, Dublin, Kyiv or New York, are in the same position as everyone else; the Act does not distinguish. A non-UK resident director verifies in one of two ways. The first is directly with Companies House through GOV.UK One Login. Companies House's guidance (updated 30 April 2026) lists a biometric passport from any country among the accepted photo identification, while the bank-details and Post Office routes are for people who live in the United Kingdom, so a non-UK director without accepted photo identification will in practice use the second route. The result of verification is a personal code that the director keeps and that the company's filing agent needs to link the verified identity to each role: in the appointment filing for a new director, in the company's next confirmation statement for an existing one, and in a separate submission for a PSC. The second route is through an authorised corporate service provider, typically the UK law firm, accountant or company-secretarial provider that already acts for the subsidiary, which carries out the check under its own anti-money-laundering supervision and confirms it to the registrar. For a group with several UK subsidiaries and the same individuals on each board, verification is done once per individual; the personal code is then used for every company, although a verification can lapse and have to be redone under section 1110A(6) and (7) and regulations 13 and 14 of SI 2025/50.

Two practical points follow for group structures. The first is sequencing: the confirmation statement date of each UK subsidiary is the real deadline, and a group with statements falling in October and November 2026 has little time. The second is the corporate-director question. Sections 156A to 156C of the Companies Act 2006, which would require every director to be a natural person subject to exceptions, are in force only for limited purposes and the prohibition itself has not been commenced, so a group that uses a corporate director on a UK board may still do so, subject to the requirement in section 155 that at least one director be a natural person; the individuals behind a corporate director are not themselves within section 167M in that capacity, but every natural-person director on the same board is.

Enforcement has started

Companies House's published approach to non-compliance (updated 5 December 2025) puts education and support before enforcement, and its campaign page said of 18 November 2025 that the date was not a deadline. The tone changed in September. On 17 September 2026 the Insolvency Service and Companies House announced the first convictions: in prosecutions brought by the Insolvency Service, three directors of two companies were fined at City of London Magistrates' Court on 16 September 2026, and both companies were also convicted of failing to deliver confirmation statements on time. The fines were modest. In our judgement the larger commercial cost lies in a confirmation statement that cannot be delivered and a register entry that lenders and buyers will see. Alongside the offence, the registrar may impose a financial penalty (section 1132A), and Companies House says it may annotate the register and refer directors who continue to act unverified to the Insolvency Service.

Companies House has said that identity verification for people who file on behalf of companies, the presenter stage, will start no earlier than November 2027, with at least six months' notice, and the corporate-director prohibition has no commencement date. The autumn of 2026 concerns directors and PSCs, with the confirmation statement as the enforcement point.

A programme for the next eight weeks

For a group with UK subsidiaries the sequence is short. List every UK company, its confirmation statement review date and the fourteen-day delivery window that follows. List every natural-person director and every registrable PSC of each, and mark those who are both. Obtain or confirm the personal code of each director, and verify those who have not done so, choosing between the GOV.UK One Login route and an authorised corporate service provider by reference to the documents each individual holds and the time available. Diarise the remaining birth-month windows for PSCs who are not directors, which for November birthdays close in the middle of November 2026; PSCs born in December to September whose windows have passed are already out of time. Diarise, for each director-PSC, the fourteen days after the end of the company's review period. Give the filing agent the personal codes before the statement is prepared. And record, for each company, who confirmed what and when, because the statement that each director's identity is verified is the company's own statement, made under the Act, and the board should be able to show the basis for it.

In our judgement the groups at greatest risk are those whose UK companies are dormant or holding entities with non-executive, non-UK boards and a filing agent that has not been told who the directors are in practice. Those boards have statements falling due this autumn like everyone else, and the confirmation statement duty under regulation 4 makes no exception for inactivity.

What this means for you

• Your deadline is your confirmation statement, not 17 November. Regulation 4 of SI 2025/1118 ties an existing director's deadline to the company's next confirmation statement (its delivery or, if it is late, the end of its delivery period), and Companies House states that it will not accept the statement until all directors have verified. Look up each company's review date now.
• PSCs run on a different clock. An existing PSC who is not a director must provide the verification statement, in practice the personal code, in the fourteen days at the start of his or her birth month, between December 2025 and November 2026, and can verify beforehand; a PSC who is also a director has a separate fourteen-day window starting the day after the company's review period ends, and the duty to deliver the statement is the PSC's own.
• Non-UK directors have no exemption and two routes. GOV.UK One Login with a biometric passport, or an authorised corporate service provider. One verification and one personal code serve every UK company the individual sits on.
• By 2 December 2026 at the latest, and for most companies much earlier, section 167M applies to every director who is an individual. An unverified individual may not act, the company may not allow it, and both commit an offence, subject only to a section 1110C exemption; the director's acts remain valid under section 167M(6), the registrar may impose a financial penalty and Companies House may annotate the register.
• Enforcement has begun. The Insolvency Service and Companies House announced the first convictions on 17 September 2026. In our judgement the larger cost is a confirmation statement that cannot be delivered and a register entry that a bank or a buyer reads.

Isak Legal advises international groups on their English subsidiaries, including board composition, Companies House filings, PSC analysis and the duties of directors appointed from outside the United Kingdom, working with the group's UK company-secretarial provider where filings are made. See our Corporate and United Kingdom pages, or get in touch.

This client update is provided for general information only, reflects the position as at 22 September 2026 and does not constitute legal advice or create a lawyer-client relationship. The statutory position is taken from sections 155, 156A, 167G, 167M, 790LB, 790LM, 790LN, 790LQ, 1098A, 1110A, 1110C and 1132A of the Companies Act 2006 as amended by the Economic Crime and Corporate Transparency Act 2023, and from SI 2025/50, the Economic Crime and Corporate Transparency Act 2023 (Commencement No. 4) Regulations 2025 (SI 2025/349) and SI 2025/1118. The 1 December 2026 outer limit is our reading of regulation 4(6) and is not stated by Companies House. Companies House's guidance pages and announcements are the registrar's published material and rank below the legislation; their content and dates change. Verify the current texts and your company's confirmation statement date at the official sources before acting. For advice on a specific matter, please contact us.