Identity verification – the latest position and practical lessons from early filings

Since this article was written, two things have become clear:

• the implementation timetable has moved, particularly for those who file documents at Companies House; and
• while the regime is conceptually straightforward, practical issues are emerging as individuals work through their filings.

A revised timetable: Identity verification for people filing documents pushed back to at least November 2026

One of the most significant developments since our last update is that identity verification will not become mandatory for people who file documents at Companies House until no earlier than November 2026.

Under earlier plans, identity verification for these presenters and registration of third‑party agents as Authorised Corporate Service Providers (ACSPs), was expected in spring 2026. Companies House has formally deferred this step to allow it to prioritise the director and PSC rollout. It’s not clear what this will mean for implementation of identity verification requirements for individuals holding other positions. 

What this means in practice

Directors and PSCs are already in scope and will need to verify their identity, so nothing has changed here.

Individuals who file documents in a presenter capacity (for example, operations teams or company secretarial staff who are not directors or PSCs) do not need to verify at the moment, unless they fall into another category.

Law firms, accountants and other agents can continue to file without ACSP status for now, but they will need to be ready by late 2026.

This additional preparation time is welcome, but it does not remove the need for advance planning for when the changes do go live.

Directors and PSCs: the regime is live 

Since the transition period began on 18 November 2025, directors and PSCs of existing companies have needed to consider when their obligation to provide a personal code is triggered. The timing depends on the individual’s circumstances but the deadline for completion can be checked by reviewing the public record for the relevant company on Companies House. 

It is important to comply with the deadlines for identity verification because it is a criminal offence for a director to act if they haven’t completed identity verification when required. PSCs also face criminal liability for failing to complete identity verification when required. Now, under ECCTA, Companies House has enhanced powers to impose financial penalties, pursue prosecutions or it may refer matters to the Insolvency Service.

What we are seeing in practice: common problem areas

For most people, identity verification can be completed directly with Companies House. Although the verification process itself is usually relatively straightforward, we are seeing difficulties at the point of linking an individual’s personal code to their appointment at Companies House. 

One common issue is the mismatch between an individual’s name as recorded at Companies House and the name shown on the identity documents used for verification. This can arise when a middle name is omitted from the register or an individual uses a different name in practice (for example, following marriage or because they have a preferred name). Even minor discrepancies between names will need to be explained when providing details of the personal code, so early review of the details shown on the public register is strongly recommended to avoid issues or delays when linking personal codes. 

Another difficulty is the common misconception that submitting a personal code for one role will mean that the individual has complied with their verification obligations. Identity verification is not fully complete until the individual’s personal code has been submitted for each relevant role that they hold. Where an individual holds multiple roles (for example, director and PSC, or multiple directorships with different companies), different deadlines may apply. This can result in some Companies House records showing verification as outstanding in respect of an appointment even though the person has verified their identity and provided their code for another appointment. The register will not be updated until the individual has supplied their code for that specific appointment. It also means that a person will be required to complete the linking for each role at each company at the relevant time.

When there are issues with linking the personal code to an appointment because of discrepancies on the register, this can lead to timing pressures with filing the confirmation statement, particularly if an update to the register is required e.g. in respect of an incorrect date of birth. 

Practical steps to take now

There are practical steps that can be taken now to avoid problems when it comes to providing Companies House with a personal code:

• Check the relevant filing date for each director and / or PSC role that you hold. This can be done using the “Search the register – Find and update company information” service on GOV.UK.
• Verify your identity well in advance, even if the formal deadline is months away.
• Review your personal details on the Companies House register and correct any inconsistencies in preparation for the relevant filing dates.
• Companies should prepare for their upcoming confirmation statement filings well in advance and start to collect personal codes, assuming that there may be delays where verification steps are incomplete.
• Identity verification checks should be built into onboarding processes and deal timetables. 

Looking ahead

Although the presenter regime has been delayed, identity verification is now a core compliance requirement. Businesses that are slow to act risk failing to comply with their obligations. Early preparation remains the most effective way to avoid last‑minute filing problems, missed deadlines and risks of enforcement.

If you would like to discuss how these changes affect your organisation or clients, or would like help navigating a specific filing issue, please contact Irwin Mitchell’s Corporate Team.