ECCTA Incoming: Mandatory ID verification goes live

ID verification becomes mandatory from 18 November 2025

The move towards enhanced corporate transparency under the Economic Crime and Corporate Transparency Act 2023 (“ECCTA”) continues with mandatory identity verification for directors, persons with significant control (PSCs) and members of LLPs being introduced from 18 November 2025. Voluntary ID verification has been available since 8 April 2025 to give the estimated 6 to 7 million affected individuals as much time as possible to comply with the requirements before the end of the transition period in November 2026. However, the introduction of mandatory verification on 18 November 2025 marks a decisive step in the implementation of these reforms.

Who will need to verify and when?

From 18 November 2025, mandatory identification requirements will apply to the following individuals: 

• Directors or their equivalents, such as members of LLPs. All newly appointed directors of companies, as well as equivalent positions, such as members of LLPs, will need to verify their identity on incorporation of a new entity or upon their appointment to an existing one. For those already in post, identity verification must be confirmed when the company files its next annual confirmation statement after 18 November 2025. At that point, directors will need to provide their unique personal codes.
• Directors of overseas companies with a UK establishment. A director of an overseas company that is registering a UK establishment with Companies House will need to verify their identity in the same way as a new director of a UK company. Existing directors will need to complete identity verification by the first anniversary of the date that the UK establishment was registered.
• PSCs. Individuals who become PSCs from 18 November 2025 can provide their personal code when they’re first added to the Companies House register or within 14 days of being added to the register. For existing PSCs, the position varies depending on whether they are also a director of the company or not. An individual who is both an existing director and a PSC of the same company before 18 November will need to provide their personal code through a dedicated service within 14 days of the company’s confirmation statement date (in addition to providing the code in their capacity as director in the company’s confirmation statement). An individual who is an existing PSC but not a director of the same company will need to provide their personal code within the first 14 days of their birth month. 

Identity verification will also be required for people who file documents at Companies House, limited partnerships, corporate directors of companies, corporate members of LLPs and officers of corporate PSCs although these requirements will commence later.

How to verify

Individuals required to verify their identity can do so directly with Companies House, using their free online service. GOV.UK One Login will ask various questions to determine the most suitable method for the individual to verify their identity. Alternatively, individuals have the option to appoint an Authorised Corporate Service Provider (ACSP) to carry out the verification process on their behalf.

Once verification has been successfully completed, Companies House will issue a unique personal code. This code will be required as proof of identity verification in respect of any roles held by the individual as director (or equivalent) or PSC. It should be kept secure and only shared with trusted advisors. 

Failure to comply 

From 18 November 2025, it is a criminal offence for an individual to act as a director (or equivalent position) without having completed the required identity verification. Failure to comply could also mean that the company or entity itself, along with other officers, may be committing an offence.

To avoid these risks, companies should review and update their onboarding procedures to ensure all newly appointed directors have completed identity verification and provided their unique personal code before commencing their duties. This proactive approach will help ensure compliance with legal obligations and avoid potential penalties.

Similarly, PSCs must also verify their identity. Failure to do so, without a reasonable excuse, will constitute an offence. It is therefore crucial for both companies and individuals to be aware of, and adhere to, these new requirements.

Other changes 

Changes to statutory registers are also being introduced from 18 November 2025. Companies are no longer required to maintain their own registers of directors, directors’ residential addresses, secretaries, or PSCs. Instead, all such details must be submitted and maintained directly with Companies House. 

Additionally, companies will no longer have the option to keep certain information on the central register at Companies House. Despite this change, the obligation to keep a register of members remains. This means that while the responsibility for holding information about directors and PSCs will transfer to Companies House, companies must continue to hold and maintain their register of members, ensuring that it is accurate at all times.

Next steps under ECCTA 

While 18 November 2025 marks a significant milestone in the implementation of ECCTA, there are still more changes to come. We will continue to share updates as more information becomes available. In the meantime, if you have any questions or wish to discuss how these developments may affect your company, please do not hesitate to contact our Corporate Team.

More information about identity verification is available in our factsheet