Last updated: 28 August 2026
Companies House identity verification is the legal requirement, in force since 18 November 2025 under the Economic Crime and Corporate Transparency Act 2023, for every UK company director, person with significant control and LLP member to prove who they are and link that proof to their appointments. The transition period for existing appointments ends in mid November 2026. But 18 November 2026 is almost certainly not your deadline, and treating it as one is the single most expensive mistake being made on this topic right now.
Companies House has been explicit. Its own campaign guidance states that 18 November 2025 is not a deadline, it is the start of a twelve month transition period, and that individuals must verify by their due dates. For a director, that due date is your company’s next confirmation statement. For a PSC who is not a director, it is the first fourteen days of your birth month. Neither of those is in November for most people.
The numbers say the message has not landed. Companies House management information published on 30 July 2026 shows that by the end of June 2026, only 55% of directors, 50% of LLP members and 42% of PSCs had told Companies House about a verified identity. Against an estimated six to seven million people who need to complete the process, that leaves a very large amount of work in a short window.
This guide sets out what the rules actually say, when each type of person is genuinely due, what happens when someone misses their date, and what an accountancy practice needs to do operationally between now and November. Every date and rule below was checked against Companies House and GOV.UK guidance in August 2026, and where official sources currently disagree with each other, which they do on one point, that is flagged rather than smoothed over.
Key takeaways
- The transition end date is a backstop, not a deadline. Your real due date is driven by your confirmation statement date if you are a director, or your birth month if you are a PSC and not a director. Most fall well before November 2026.
- One unverified director blocks the whole filing. A confirmation statement cannot be filed without a personal code for every director, and failing to file a confirmation statement is itself an offence.
- If you are both a director and a PSC of the same company, you must supply your code twice. Once in the confirmation statement, and separately through the PSC verification service within a fourteen day window. One submission does not cover both roles.
- Filing your confirmation statement early does not move the PSC window. Companies House guidance is explicit on this and it catches practices that assume the two are linked.
- Just over half of directors have complied. Companies House reported 55% of directors, 50% of LLP members and 42% of PSCs verified and linked by the end of June 2026.
- Enforcement moves up a gear once the transition closes. Non compliance is a criminal offence, and Companies House can impose civil financial penalties of up to £10,000 per offence, alongside filing restrictions and register annotations.
- The rule about who can file has moved. Identity verification for people who file at Companies House is now stated as no earlier than November 2027, with at least six months’ notice. An older official page still says November 2026.
Is 18 November 2026 the Companies House identity verification deadline?
Not in the way most coverage presents it. 18 November 2025 was the date identity verification became a legal requirement, and it started a twelve month transition period that closes in mid November 2026. Some sources put the last day at 17 November 2026 and some at 18 November 2026. That distinction rarely matters, because the transition end is a backstop for the whole population rather than a due date for any individual.
The Companies House campaign site puts it plainly: the 18 November 2025 date is not a deadline, it marks the start of a transition period giving companies time to make sure directors and PSCs have verified by their due dates. The word doing the work in that sentence is “their”.
Look at the current GOV.UK guidance on when you need to verify your identity, last updated on 30 July 2026, and the November date does not appear in the director rules at all. What appears instead is a trigger: you provide your personal code as part of your company’s next confirmation statement. A company with a confirmation statement date in September 2026 has a September deadline. A company that filed in July 2026 without codes has already missed one.
This matters commercially as well as technically. A practice that has told clients “you have until November” has given them a date that is later than their real one in most cases, and there is no mechanism to extend a confirmation statement date to buy time.
When does each type of person actually need to verify?
The rules differ by role, and by whether the person was in post before or after 18 November 2025. This table restates the current GOV.UK position.
| Role | When the code must reach Companies House | Route used |
|---|---|---|
| Existing director | As part of the company’s next confirmation statement, for each company you are a director of | Confirmation statement |
| New director or new incorporation | Before appointment. A personal code is required for each director as part of the registration filing | Incorporation or appointment filing |
| Director and PSC of the same company | The code goes in the confirmation statement for the director role, and separately within 14 days starting the day after the confirmation statement date for the PSC role | Two separate submissions |
| PSC who is not a director of that company | Within the first 14 days of your birth month. A 22 January date of birth gives a window of 1 to 14 January | Provide identity verification details for a PSC |
| Person who became a PSC after 18 November 2025 | When first added to the register, or within 14 days of being added | PSC verification service |
| LLP member | Same regime as directors, tied to the LLP’s confirmation statement | Confirmation statement |
| Overseas company director | All directors must be confirmed as verified by the anniversary of the UK establishment’s registration | UK establishment filing |
The incorporation rule is the one with the hardest edge. You cannot register a new UK company at all unless every proposed director already holds a personal code, which changes the sequencing of a company formation. Anyone still working from an older process, including the steps in our guide to setting up a UK limited company, needs to add verification as step one rather than an afterthought.
Two details in that table are missed constantly and both come straight from the guidance.
Filing the confirmation statement early does not move the PSC window. If a company brings its confirmation statement forward, the fourteen day PSC period still runs from the original confirmation statement date. A practice that files a batch of statements early in October to clear the desk has not moved a single PSC deadline.
A dual role person needs two submissions, not one. Providing a personal code in the confirmation statement satisfies the director obligation only. The PSC obligation is discharged separately through the Provide identity verification details for a PSC service. This is the most common cause of a person believing they are compliant when the register says otherwise.
The registrar has discretion to extend a PSC due date by up to fourteen days, and a PSC remains compliant where that extension is granted. It is a safety valve, not a plan.
Who has to verify, and who does not yet?
Identity verification currently applies to new and existing directors, new and existing PSCs, and members of limited liability partnerships. It does not currently apply to shareholders who are not PSCs, to employees, or to company secretaries who hold no other in scope role.
Several categories are still to come, and the timetable for the largest one moved this summer.
| Category | Current position | Notes |
|---|---|---|
| Directors, PSCs, LLP members | In force since 18 November 2025 | Transition for existing appointments closes mid November 2026 |
| People who file at Companies House | No earlier than November 2027 | At least 6 months’ notice promised before it takes effect |
| Limited partnerships | Later date, not announced | Sits alongside wider limited partnership reform |
| Corporate directors of companies | Later date, not announced | Individual officers of the corporate director will be in scope |
| Corporate members of LLPs | Later date, not announced | Same principle as corporate directors |
| Officers of corporate PSCs | Later date, not announced | Verification pushes through to the individuals behind the entity |
On the second row, official guidance currently contradicts itself and it is worth knowing which page is newer. The Companies House identity verification page, modified on 5 August 2026, states that verification for people who file will come in no earlier than November 2027. The separate Authorised Corporate Service Providers campaign page still says businesses will need to be registered as an ACSP to file on behalf of clients from no earlier than November 2026. The August update is the more recent position and matches the revised outline transition plan published the same week.
If your firm has been budgeting for a hard November 2026 cut off on third party filing, that assumption is worth revisiting. It has moved by roughly a year. It has not been cancelled.
How do you verify your identity for Companies House?
There are two routes and they end in the same place: a Companies House personal code issued to you as an individual.
Route one is direct, through GOV.UK One Login. You use the verify your identity for Companies House service with photo ID such as a passport or UK driving licence. For someone with a valid biometric passport and a smartphone, this is usually a single sitting. Where the digital check cannot complete, identity can be proved in person at the Post Office, which is the fallback that matters for older directors, people without a current passport and anyone whose documents do not match the register.
Route two is through an Authorised Corporate Service Provider. An ACSP, also called a Companies House authorised agent, is an AML supervised firm such as an accountant, solicitor, chartered secretary or company formation agent that has registered with Companies House and can verify clients on their behalf. Checks carried out by an ACSP must meet the same standard as direct verification.
Neither route is inherently better. The direct route is free and fast for a straightforward case. The ACSP route matters when a client cannot complete the digital check, when a firm wants control of the evidence and the timing across a portfolio, or when the client simply will not do it themselves without someone sitting with them.
A practical point on sequencing. Verification and linking are two different steps. Verifying gets you a personal code. The obligation is only discharged when that code reaches Companies House against the right role. A client who tells you they have “done the ID check” has completed step one and may not have completed step two.
What is a Companies House personal code and how is it used?
A Companies House personal code is a unique identifier issued to an individual once their identity has been verified. It attaches to the person, not to a company or an appointment, which has three consequences worth spelling out.
- You verify once, and reuse the code. A director of nine companies verifies a single time and supplies the same code against each appointment. There is no need to repeat the identity check per company.
- You still have to supply it separately for every company and every role. Verifying once does not populate anything automatically. Nine directorships means nine confirmation statements carrying the code, and a dual role means a further submission per company.
- It is personal data and should be handled as such. Companies House guidance on personal codes treats the code as confidential to the individual. A practice collecting codes across a client base is holding a register of them and needs to think about storage, access and retention in the same way it would for any other identifier.
That third point deserves more attention than it is getting. Firms are collecting hundreds of personal codes into spreadsheets and email threads. If your practice is doing that, the codes belong in your practice management system with proper access controls, not in an inbox.
How is compliance actually going?
Slowly, and the published data is unusually good for a reform this recent because Companies House now reports quarterly.
| Measure | Figure | Source and date |
|---|---|---|
| Directors who had informed Companies House of a verified identity | 55% by end of June 2026 | Companies House management information, published 30 July 2026 |
| LLP members verified and linked | 50% by end of June 2026 | Same publication |
| PSCs verified and linked | 42% by end of June 2026 | Same publication |
| Individuals expected to need verification | 6 to 7 million by mid November 2026 | Companies House estimate |
| Individuals verified and linked in total | Nearly 4 million | Third ECCTA progress report, 11 June 2026 |
| Individuals verified by ACSPs | 783,000 by 31 March 2026 | Third ECCTA progress report |
| ACSPs suspended, and registrations ceased | 74 suspended, 56 ceased | Third ECCTA progress report |
| Non compliance letters issued November 2025 to May 2026 | 983,000 | Companies House data obtained under FOI by Spotlight on Corruption |
Read those rows together and a clear picture emerges. Roughly three in ten directors and more than half of all PSCs still had work to do at the end of June. Nearly a million non compliance letters had already gone out. And Companies House has been running a supportive posture while it prepares to switch to enforcement, with its 2026 to 2027 business plan committing to proportionate action against those who fail to verify.
The PSC figure is the one that should worry a practice most. PSCs who are not directors sit outside the confirmation statement workflow entirely, run on a birth month clock nobody is watching, and are frequently people the practice has less contact with: a founder who stepped back, a spouse holding shares, a parent company’s beneficial owner.
What happens if someone misses their date?
Four things, in escalating order, and the first one bites immediately regardless of enforcement posture.
The filing is blocked. A confirmation statement cannot be submitted without a personal code for every director. One unverified director stops the entire filing, and failing to file a confirmation statement is a separate offence that can lead to strike off proceedings. The compliance failure therefore compounds into a second, more serious one.
It is a criminal offence. Acting as a director without having verified is an offence under the Act, and the company can also commit an offence. ICAS has summarised the enforcement approach, noting that where there is evidence of deliberate evasion, escalation to criminal prosecution under the Companies Act 2006 is possible.
Civil financial penalties apply. Since 2 May 2024, Companies House can impose financial penalties for most Companies Act offences without going to court. The published approach to financial penalties sets out fixed penalties, daily rate penalties or a combination, and no single penalty may exceed £10,000.
| Seriousness of offence | Indicative fixed penalty range | Escalation |
|---|---|---|
| Minor | From around £250 | Rises with repeat offending in the previous 5 years |
| Serious | From around £750 | Rises towards the upper range for repeat offenders |
| Very serious or repeated | Up to around £2,000 per offence | Daily rate penalties can run alongside the fixed amount |
| Any single offence | Capped at £10,000 | Cannot exceed the maximum fine for the underlying offence |
The register records it. Non compliance can be annotated publicly, and in serious cases directors face disqualification. For a company in the middle of a funding round, a sale or a lending application, a register annotation is a commercial problem long before it becomes a legal one.
Worth being precise about the current position: penalties are available now, but Companies House has been operating supportively through the transition. That posture changes when the transition closes, and there is no indication of a further grace period afterwards.
What must an accountancy practice actually do before November?
Treat it as a portfolio sweep keyed to confirmation statement dates, not as a client by client conversation. A practice with three hundred company clients has roughly six hundred to nine hundred individuals in scope, spread across twelve months of due dates, and it cannot be worked reactively in the week each statement falls due. It also has to fit around everything else in the autumn, and the UK tax year 2026/27 key dates calendar shows how little clear space there is between September and January.
Here is the sweep we would run, and it takes a day of admin time rather than a project.
- Step 1. Export every client company with its confirmation statement date. Sort by date. Everything falling in the next twelve weeks is your working list. Everything already past without codes is a remediation list, and that one goes first.
- Step 2. Count individuals, not companies. For each company, list every director, every PSC, and every LLP member. Flag the people who hold both a directorship and a PSC interest in the same entity, because those need two separate submissions and they are the most common false positive on any compliance tracker.
- Step 3. Build a separate PSC birth month calendar. PSCs who are not directors do not appear on the confirmation statement clock at all. Sort them by month of birth and treat each month as its own small deadline. This list is the one nobody has and the one where compliance is lowest.
- Step 4. Triage into four buckets. Code held and submitted. Code held but not yet submitted against the role. Verification not started but straightforward. And hard cases: no current passport, overseas residents, clients with capacity issues, or a name or date of birth on the register that does not match their documents. The fourth bucket needs six weeks, not six days.
- Step 5. Fix register mismatches before you start the ID check. A misspelled name or an incorrect date of birth on the register will cause the link to fail after verification has succeeded, which is a frustrating way to lose two weeks. Check the register entry first for anyone in the hard case bucket.
- Step 6. Decide who chases. Verification is the client’s legal obligation, not yours, but the blocked filing is your problem. Assign an owner, set a chase cadence, and record refusals in writing.
One judgement call worth making explicitly. This work is real and it is not billed under most compliance engagements, because it did not exist when the engagement letter was written. Firms are absorbing it silently, and by November a mid sized practice will have spent a meaningful number of chargeable hours on it. Whether you charge for it or not, decide deliberately rather than by default. Our breakdown of accounting outsourcing pricing models is a useful reference point if you are costing the work out. Our note on fixed fee versus hourly billing for UK practices works through how to handle scope that appears mid year.
If the sweep shows more work than your team can absorb alongside the autumn compliance calendar, that is a capacity question rather than a technical one. The same trade offs we set out in the peak season capacity playbook apply here, and the wider context on why the preparer market is tight sits in our note on the accountancy talent shortage. If the answer is to move production work out of the firm for the autumn, our comparison of UK accounting outsourcing firms covers how the different models handle a short term peak.
Should your firm register as an Authorised Corporate Service Provider?
Registering as an ACSP lets your firm verify clients’ identities directly, which removes a dependency on clients completing GOV.UK One Login themselves. It is a modest process to start and an ongoing supervised status to maintain, and the second half is where firms underestimate it.
The mechanics are straightforward. You must be supervised in the UK by a relevant AML supervisory body, a senior person in the firm must complete their own identity verification first, and you apply through the Companies House authorised agent service. ACCA has set out the process for its members, including the £55 registration fee. Applications from firms not supervised in the UK, or supplying incorrect membership details, are rejected.
What has changed is the standard applied afterwards. Companies House published fit and proper criteria for ACSPs on 11 August 2026, covering AML supervision, criminal, regulatory and financial history including bankruptcy and director disqualification, honesty and integrity including previous dealings with Companies House, and how the ACSP actually carries out identity checks. The guidance is explicit that AML supervision alone does not satisfy the test, and it applies to existing registrants as well as new applicants.
The enforcement is not theoretical. By 31 March 2026, Companies House had suspended 74 ACSPs and ceased the registration of a further 56. Registration is a supervised status you hold, not a badge you collect.
| Register as an ACSP if | Stay off the register if |
|---|---|
| You form companies for clients and want to complete verification at incorporation | You handle a small number of company clients who can all verify themselves |
| A material share of your clients will not or cannot complete One Login unaided | Your AML supervision, record keeping or Companies House filing history would not withstand a fit and proper review today |
| You want the evidence and the timing under your own control across a portfolio | You cannot commit to retaining identity verification records to the required standard |
| You expect to keep filing on behalf of clients when that requirement arrives | You are planning to stop filing on behalf of clients anyway |
On the last row of the left column: the requirement for filers to be registered has moved to no earlier than November 2027, but the direction is settled. A firm that files at Companies House on behalf of clients as a core service will need ACSP status eventually. Doing it now, with a year of operating history behind you, is a more comfortable position than applying in the month it becomes compulsory.
One caution. Verifying a client’s identity as an ACSP is a regulated act with record keeping obligations attached, not an admin favour. If your firm takes it on, it needs a documented process and a person who owns it, in the same way the outsourced accounting quality control checklist treats review as a defined step rather than an assumption.
What do firms and directors get wrong most often?
Six errors account for nearly all of the avoidable problems we see.
Working to November instead of the confirmation statement date. The most common and the most expensive. For a company with a March confirmation statement date, November guidance was eight months too late.
Assuming one submission covers a dual role. Director and PSC of the same company means two separate submissions through two different routes. The register will show the gap even though the person has verified.
Filing the confirmation statement early to buy time on the PSC window. It does not work. The fourteen day PSC period runs from the original confirmation statement date regardless.
Confusing verification with linking. Getting a personal code is not compliance. Compliance is the code reaching Companies House against the right appointment. Plenty of clients have completed the first and not the second and believe they are done.
Ignoring PSCs who are not directors. They are outside the confirmation statement workflow, they run on a birth month clock, and at 42% they are the least compliant group in the data.
Leaving hard cases until last. The client without a current passport, the overseas director, the person whose name on the register does not match their documents. These need weeks, not days, and they are always discovered late because the easy cases get done first.
Getting this closed before the transition ends
Identity verification is not technically difficult. It is an administrative problem with a hard edge, and the edge is that a missing personal code stops a statutory filing that carries its own offence. That combination is what turns a five minute task into a compliance failure.
If you run a company, the next step is to find your confirmation statement date, list every director and PSC, and work out whether any of them holds both roles. If you are a PSC and not a director, find your birth month window and put it in your calendar now rather than next January.
If you run a practice, run the portfolio sweep. Export confirmation statement dates, build the separate PSC birth month calendar, and triage into the four buckets. The hard cases are the ones that determine whether November is comfortable or not, and you will not find them without looking.
Acenteus Accounting supports UK accountancy practices with the compliance production work that sits underneath this: statutory accounts production, tax compliance outsourcing, accounting outsourcing for accountants and audit support, so your qualified people have the hours to run a sweep like this rather than choosing between it and the filing calendar. If capacity between now and November is the real constraint, talk to our team and bring the actual constraint rather than a brief.
Frequently Asked Questions (FAQ)
A legal requirement under the Economic Crime and Corporate Transparency Act 2023 for individuals who set up, run, own or control UK companies to prove their identity to Companies House. It applies to directors, people with significant control and LLP members, and has been mandatory since 18 November 2025. Once verified, the individual receives a Companies House personal code.
No. It marks the end of the twelve month transition period for existing appointments, but individual due dates fall earlier for most people. Directors must supply their personal code with their company’s next confirmation statement, and PSCs who are not directors have a fourteen day window in their birth month. The transition end is a backstop, not a personal deadline.
The confirmation statement cannot be filed. A personal code is required for every director, so a single unverified individual blocks the filing for the whole company. Because failing to file a confirmation statement is itself an offence that can lead to strike off proceedings, one person’s inaction becomes the company’s legal problem.
You verify once and receive one personal code, but you must supply it twice. Once in the company’s confirmation statement for your director role, and separately through the PSC verification service within fourteen days starting the day after the confirmation statement date. One submission does not discharge both obligations.
No. Companies House guidance states that if a company files its confirmation statement early, the dates of the PSC fourteen day period do not change. The window runs from the original confirmation statement date.
You can prove your identity in person at the Post Office using the Companies House service, or you can verify through an Authorised Corporate Service Provider such as an accountant or solicitor registered with Companies House. Both routes meet the same standard as the digital check through GOV.UK One Login.
Only if they are a person with significant control. Ordinary shareholders who do not meet the PSC conditions, employees and company secretaries who hold no other in scope role are not currently required to verify.
Not to continue filing today. Registration is required if you want to carry out identity verification checks on clients on the firm’s behalf. Companies House has said that in future anyone filing on behalf of clients will need to be registered, and its most recent guidance puts that at no earlier than November 2027 with at least six months’ notice.
There is a £55 registration fee. The firm must be supervised in the UK by a relevant anti money laundering supervisory body, and a senior person such as a director, partner or sole trader must complete their own identity verification before applying. Applications are refused where the applicant is not considered fit and proper.
Non compliance is a criminal offence. In practice the first consequence is that filings are blocked. Companies House can also impose civil financial penalties, which may be fixed, at a daily rate, or a combination, and cannot exceed £10,000 for any single offence. Non compliance can be annotated on the public register, and in serious cases directors face disqualification.
Companies House management information published on 30 July 2026 showed that by the end of June 2026, 55% of directors, 50% of LLP members and 42% of PSCs had informed Companies House of a verified identity. Its third ECCTA progress report, published on 11 June 2026, put the total number of individuals verified and linked at nearly four million against an estimated six to seven million in scope.
Not directly. It is a Companies House requirement under company law, entirely separate from HMRC obligations, and it does not change any tax deadline. The practical overlap is that it competes for the same team time as the tax and accounts calendar, and a blocked confirmation statement can create wider compliance problems for a company. HMRC is running its own separate digital reform programme, and the position on companies specifically is covered in our Making Tax Digital for Corporation Tax guide. For HMRC contact routes and agent authorisation, which are also separate from Companies House, see our guide to contacting HMRC about Corporation Tax.
