Partner London
"Although certain aspects of the IDV process are yet to be finalised, early preparation will be crucial."
Identity verification (“IDV”) is the process of confirming that a person is who they claim to be. The aim of the IDV regime is to reduce the risk of fraud by making it harder to register fictitious directors and beneficial owners and to improve the integrity and accuracy of the public record at Companies House.
Although certain aspects of the IDV process are yet to be finalised, early preparation will be crucial. The key requirements are summarised below.
Who needs to have their identity verified?
The new IDV requirements will apply to:
- all new and existing directors of UK companies;
- all new and existing individual members of an LLP and, in relation to each corporate member, a nominated director;
- all new and existing persons with significant control (“PSCs”) of a company or LLP;
- an individual who is a relevant officer of a registrable relevant legal entity (RLE) of a company or LLP;
- a nominated director of each corporate general partner of a limited partnership; and
- individuals filing information at Companies House, whether on their own behalf or on behalf of another.
The new IDV requirements will also apply to directors of overseas companies that are registered at Companies House. The timing of implementation will be the same as for UK companies but with specific transitional provisions for existing directors of overseas companies.
What is the implementation timeline?
The current proposed timeline is as follows:
- 8 April 2025 – voluntary IDV for individuals was introduced;
- Autumn 2025* – IDV will become compulsory for directors, LLP members and PSCs in connection with incorporation and new appointments. A 12-month transition period will also begin in respect of existing directors, LLP members and PSCs during which time any relevant individuals must verify their identities by the time the company or LLP files its next confirmation statement;
- Spring 2026* – IDV will become compulsory for those filing documents at Companies House. Any third parties who are filing on behalf of a company will need to register as an authorised corporate service provider (“ACSP”); and
- by the end of 2026 – the 12-month transition period will end and Companies House will start their compliance checks. IDV will come into force for limited partnerships.
*Companies House has not yet indicated a more specific date.
How can you verify your identity?
There are two routes to complete IDV:
- with Companies House directly, at no cost; or
- via an ACSP, for a fee (to be decided by the relevant ACSP).
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"The route chosen determines which identity documents need to be provided."
The route chosen determines which identity documents need to be provided. In certain cases, direct verification with Companies House will not be available to an individual if they are unable to provide the required form of identity documents.
Companies House route
The Companies House route provides three separate methods of IDV:
- GOV.UK One Login Check app – this allows the following forms of identity to be used: (i) biometric passport (not expired); (ii) UK photocard driving licence (full or provisional); (iii) UK biometric residence permit (up to 18 months expired) or UK biometric residence card; and (iv) UK Frontier Worker permit. The applicant will need to access a suitable smart phone with a working camera and download the app;
- GOV.UK One Login web service – this allows the following forms of identity to be used: (i) UK passport (up to six months expired); (ii) UK photocard driving licence (full or provisional); and (iii) UK bank account with national insurance number. Certain security questions will also be asked which only the applicant should know the answer to; and
- Face to face service (at selected post offices) – this allows the following forms of identity to be used: (i) biometric passport (up to 18 months expired); (ii) non-biometric passport from selected countries (up to 18 months expired); (iii) UK or EU photocard driving licence (full or provisional), (iv) UK biometric residence permit (up to 18 months expired), and (v) biometric EEA national identity photocard. Applicants must also have a UK home address. For this route, the application is initiated and completed through the GOV.UK One Login website, but the information must be submitted in person at a chosen post office.
ACSP route
A wider range of documents can be provided if using the ACSP route, but the exact requirements will depend on what process the ACSP uses to carry out IDV. If using technology that can validate cryptographic features, one of the following can be used: (i) biometric or machine-readable passport or Irish passport card (up to six months expired); (ii) UK, Isle of Man, Channel Islands or EU photocard driving licence (full or provisional); (iii) EU or EEA biometric identity card; (iv) UK biometric residence permit (up to 18 months expired) or UK biometric residence card; and (v) UK Frontier Worker permit. Where an ACSP cannot validate cryptographic features, two pieces of evidence from a specified list will be required (one of which must be photographic, and, where a person does not live in the UK, one must be a government-issued document).
Once an ACSP has completed IDV it will deliver a verification statement to Companies House confirming this. This will include certain personal details relating to the individual, what documents were used as evidence and certain details such as document reference number or equivalent, expiry date and country of issue (but copies of documents will not need to be submitted).
Note that Watson Farley & Williams will not be providing IDV services for clients. However, we can provide contact details for certain providers that are registered as ACSPs and are offering IDV services. Please let us know if you would like us to provide details or put you in touch with any of these companies.
"Watson Farley & Williams will not be providing IDV services for clients. However, we can provide contact details for certain providers that are registered as ACSPs and are offering IDV services."
What happens when you verify?
When IDV has been successfully completed, Companies House will issue an 11-character unique identifier known as a Companies House personal code to the individual in question. This personal code will not be disclosed publicly by Companies House and should be kept securely. If an individual verifies via an ACSP, they will receive an email containing their personal code. If they verify directly with Companies House, they will see the personal code on screen (and should screenshot it for their records). They should then be able to view their personal code in the “manage account” section of their Companies House account.
This personal code will be used to connect an individual’s verified identity with the records at Companies House for each of the roles they hold (e.g. from Autumn 2025, existing directors will need to provide the personal code as part of a company’s confirmation statement filing, new directors will need to provide it on appointment and directors will need to provide it when incorporating a company).
How is your personal information held?
The new IDV legislation will extend the list of materials unavailable for public inspection at Companies House to include documents and statements delivered to Companies House in connection with IDV requirements but see the approach regarding ACSPs set out below. To find out how personal information is stored and used when you verify your identity through Companies House using GOV.UK One Login, see the GOV.UK One Login privacy notice. Notably, in relation to information security, this confirms that systems and processes have been set up to prevent unauthorised access or disclosure of information – for example, using varying levels of encryption. Any third parties must also keep all personal information they process on behalf of the Governmental Digital Service secure. Users are reminded of the need to choose a strong password for their GOV.UK One Login and ensure they keep it secure.
If using an ACSP to undertake IDV, the ACSP is under an obligation to keep records of all the evidence and information used to verify someone’s identity. This must be kept for seven years from the date it completes IDV and includes copies of the documents checked, evidence of the identity checks completed and records of any failed verification attempts. In terms of the information submitted to Companies House by an ACSP, Companies House guidance confirms that once a person connects their personal code to Companies House records, the public register will show their identity verification statement that will include the person’s name, ACSP name, name of the Anti-Money Laundering supervisory body the ACSP is registered with and the date the identity checks were completed.
When might reverification be required?
"Companies House has indicated that IDV will typically only need to be completed once."
Companies House has indicated that IDV will typically only need to be completed once. However, Companies House may require an individual to re-verify their identity if there is reasonable cause to believe the information or evidence provided was misleading, false or deceptive. In such a case, it will issue a notice to the relevant individual requiring reverification within a certain period of time. Reverification will not be required just because ID documents have expired or been replaced and it is also not thought to be required on a change of name, although Companies House has yet to confirm what the process will be in such a case. The Companies House guidance very clearly states that individuals must not verify again unless Companies House tells them to do so.
What are the consequences of non-compliance?
Once IDV becomes mandatory:
- non-compliance may result in the commission of a criminal offence resulting in a fine or financial penalty. There will also be a note on the register that someone’s identity is not verified;
- if an individual acts as a director without having their identity verified, that individual, the company and any of its directors, will be committing an offence (unless an exemption¹ from verification exists). A director may also be disqualified. However, a director’s appointment will be valid and the validity of any actions taken by a director whose identity has not been verified will not be questioned just because of a lack of IDV; and
- anyone who is (or was at that time) a PSC but does not complete IDV will commit an offence.
From a practical point of view, once IDV becomes a legal requirement, a person whose identity has not been verified will not be able to be registered at Companies House as a director or LLP member on incorporation of a company or LLP as IDV must be confirmed in the application form. They will also not be able to make filings on behalf of a company once the new filing requirements come into force. Any new director being appointed to an existing company after IDV becomes compulsory will need to conduct IDV before the notice of their appointment is filed at Companies House and before they act as a director – in practice, this means IDV should be completed and confirmed before appointment to enable directors to act as soon as their appointment takes effect.
"In advance of IDV becoming mandatory, clients should consider ... completing IDV on a voluntary basis."
Practical steps to prepare for IDV
In advance of IDV becoming mandatory, clients should consider:
- reviewing, and, if necessary, updating current filings for directors and PSCs to ensure information is correct and consistent;
- identifying who will need to undertake IDV for each company (noting that IDV will only need to be completed once for each individual) and briefing relevant individuals on the requirements;
- identifying any individuals who have identity documents that may require verification through the face-to-face service or by an ACSP and asking relevant individuals to check validity of documents including relevant expiry dates;
- checking when confirmation statements are due for each company in a group (to ensure IDV can be completed in sufficient time to ensure timely filing of confirmation statements and avoid late filing penalties); and
- if relevant, completing IDV on a voluntary basis.
Conclusion
There is still more information to come from Companies House, including the specific dates when IDV will become compulsory. We intend to update this article as necessary when further material information is released.
[1] A person may be exempt from the director IDV requirements if the Secretary of State gives a written notice exempting that person if it is necessary to do so in the interests of national security or for the purpose of preventing or detecting serious crime. There are no equivalent national security exemptions to IDV for PSCs.
Key contacts
Partner London
Partner London
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Knowledge Counsel London
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Associate London
