Companies House and ECCTA: Identity verification proves to be more disruptive than expected 

At Diligent's recent event Companies House gave a candid account of where ECCTA reform currently sits. Some of it was expected, and some of it was instructive precisely because of the numbers behind it. 

The strategic framing of Companies House has begun to shift. Their five-year strategy published in October 2025 makes clear that Companies House sees itself moving away from being a passive filing repository and more as an active gatekeeper of company information. The practical expression of that is establishing a tighter grip on who can file on behalf of companies and how. 

The most significant structural change since the passing of ECCTA was the introduction of Authorised Corporate Service Providers (ACSPs) . Shortly, anyone filing on behalf of a company will need to be either a registered ACSP or a verified employee of the company. That changes how filing processes need to be organised, and it narrows the margin for informal or delegated arrangements that many teams have previously relied on. 

On identity verification, the numbers are sobering. Since the voluntary window opened in April 2025, Companies House has issued approximately 4.5 million verification codes to directors and PSCs. Only 47% of directors have actually included their codes in CS01 filings, with on-time CS01 filing compliance dropping to 55%. Those two figures together suggest the IDV requirement is disrupting normal filing behaviour more than anticipated. 

The reported barriers are practical rather than wilful, with OneLogin causing problems for some users and directors without biometric passports facing challenges with verification too. Companies House acknowledged these issues at the event and pointed to the ACSP route and an accessible process option as alternatives. For any team managing a large director population, proactive support and early outreach will reduce the need for significant rework. 

Further reforms, including the electronic filing of statutory accounts, are on the horizon, but not imminently. Companies House confirmed at least 21 months' formal notice before any mandate, putting implementation no earlier than April 2028. The current paper-based filing process is recognised as a huge source of delay and resource at Companies House, particularly for larger groups with subsidiary account obligations.  

For teams managing entity portfolios, the practical read from the Companies House update is this: filing processes need to be reviewed against the ACSP requirements now, not when the mandate bites. Director verification codes need to be chased down and added to CS01 filings, with support available for those hitting OneLogin or passport-related issues. And the drop in on-time compliance is worth taking seriously as a signal that the reforms are putting organisations under pressure across the board. 

Law Debenture is a registered ACSP and provides identity verification for UK directors, PSCs, and LLP members. We also provide entity management and corporate secretarial services across the UK and 120+ jurisdictions. If any of this is relevant to how your organisation is managing ECCTA obligations, get in touch: lauren.geary@lawdeb.com