By Lauren Geary, Senior Manager

Three months from now, the 12-month transition period for Companies House identity verification closes. The deadline is 17 November 2026, and the numbers suggest a significant proportion of UK company directors, PSCs, and LLP members have yet to act.

Companies House estimates that roughly 6 to 7 million existing individuals need to complete verification before that date. According to management information published by Companies House on 30 July 2026, covering April to June 2026, only 55% of directors, 50% of LLP members, and 42% of PSCs had informed Companies House of their verified identity by the end of June. That means, on current figures, approximately three in ten directors and more than half of all PSCs still need to complete the process in the time remaining.

For teams managing large director or PSC populations, that is a substantial operational task. And unlike filing a confirmation statement or updating a registered address, identity verification cannot simply be delegated and ticked off. Each individual must go through the process themselves.

What is required and who is in scope

Identity verification was introduced under the Economic Crime and Corporate Transparency Act 2023 (ECCTA). The requirement applies to:

• Company directors

• Persons with Significant Control (PSCs)

• LLP members

It applies regardless of nationality or country of residence. An overseas director of a UK-registered company is in scope in exactly the same way as a UK-based one, which is one reason the coordination challenge is more complex than it might initially appear.

Once verified, each individual receives a Companies House personal code. That code must be submitted alongside a verification statement when it is included in filings. For existing directors, the code is required at the point of filing the company's next confirmation statement. For existing PSCs who are not also directors, the window is tied to the first 14 days of the individual's birth month as it appears on the register.

The two routes to verification

GOV.UK One Login

The direct route through GOV.UK One Login is free and, in straightforward cases, can be completed in a few minutes via an app. It requires a biometric passport. For those without one, or where the app-based process fails, an in-person option at Post Office locations is available, though this adds time and coordination.

Authorised Corporate Service Provider (ACSP)

The ACSP route is the alternative for individuals who cannot complete verification directly, or where organisations want professional support to manage the process at scale. ACSPs can verify individuals in over 120 countries, with no requirement for the individual to travel to the UK. This route is particularly relevant for international directors, individuals with complex name histories or address records, and cases where the GOV.UK One Login system has returned rejections.

The most common reasons for rejection through the direct route include: document types not accepted by the GOV.UK system, international documents not recognised, and technical issues with app-based verification. Companies House has acknowledged these issues and has consistently pointed organisations towards the ACSP route where the direct process is not working.

What happens if verification is not completed by 17 November 2026

Acting as a director without having verified identity is an offence under ECCTA. Companies House has been clear that it intends to move from a supportive to an enforcement footing once the transition period closes. Its 2026-27 business plan sets a target that all companies will have met identity verification requirements linked to their confirmation statement, or be on an appropriate pathway to compliance or enforcement action, by the end of the financial year.

Practical consequences for non-compliance include restrictions on Companies House filings, financial penalties, difficulties making new appointments or changes, and public marking on the register. In serious cases, disqualification or further legal action is possible.

There is no indication that a significant grace period will follow the close of the transition window so the time to act is now.

What organisations should do immediately

For any organisation with a portfolio of entities, the priority is identifying where the gaps are. That means:

• Auditing which directors, PSCs, and LLP members across the portfolio have yet to confirm their identity to Companies House

• Identifying individuals who are likely to face difficulties with the direct GOV.UK route - international directors, those without biometric passports, or those who have previously had applications rejected

• Building a realistic timeline for the remaining three months that accounts for the coordination effort involved in reaching and supporting senior individuals

• Not underestimating the task: with multiple roles across multiple entities, the number of individual verification actions required can be substantially larger than the number of individuals involved

The earlier this work starts, the more options there are. Leaving this task to November creates real risk of not completing in time, particularly for complex international cases that may require additional document checks or follow-up.

Law Debenture is a registered ACSP and provides identity verification for UK directors, PSCs, and LLP members across 120+ jurisdictions, with no UK visit required. We also provide entity management and corporate secretarial services across the UK and internationally. If you need support completing verification before the November deadline, please get in touch: lauren.geary@lawdeb.com

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