Policy & Compliance
The Economic Crime and Corporate Transparency Act 2023 introduced the concept of mandatory identity veri fi cation (IDV) for all UK companies. BIFA has highlighted this requirement to Members in the past and reproduces here a Guidance Note published by Birketts detailing the changes, how they will impact you and how you need to prepare. Whilst IDV is not mandatory at this time (we are currently in a ‘voluntary’ phase), it will be important to take early compliance steps to avoid the serious implications of non-compliance. Verifying the identity of directors and PSCs at Companies House
Who needs to verify their identity? T he following people associated with your their identity: • Directors; • Persons with significant control (PSCs) who are notified to Companies House under the PSC regime – and which includes a relevant officer of a Relevant Legal Entity (RLE); • Anyone within your company who may make filings at Companies House on your behalf (in addition to the filing work completed by company will need to verify others on your behalf, eg accountants) – we do not anticipate this particular requirement taking effect until spring 2026. Timing Mandatory IDV of directors, PSCs and RLEs is due to take effect “by autumn 2025” (no precise date has yet been announced). Once in force the implications for your company are: • Newly appointed directors of your company (those appointed after mandatory IDV takes effect) will not be able to act unless their identity has first been verified; • It will not be possible to incorporate a new company (should you wish to do so) unless the directors have first been identity verified; • For all existing directors of your company, their identity must be verified by the time of filing of the next confirmation statement (CS01) after the mandatory requirements come into force.
Ways to verify identity There are two routes to IDV. • Via Companies House: this is a free-of-charge service and will require individuals to go through the GOV.UK One Login, which will then direct the individual to verify their identity online either via the mobile phone app route or web browser route. The individual will need to provide identity evidence such as biometric passport, UK photo driving licence or UK biometric residence permit. More information can be found on the government site Verify Your Identity for Companies House. • Using an Authorised Corporate Service Provider: You can ask a registered Authorised Corporate Service Provider (ACSP), also known as a Companies House authorised agent, to verify a person’s identity. Various corporate governance/ compliance entities are set up to provide this service and will charge a fee per individual they IDV. ACSPs can often co-ordinate the IDV of a group of named individuals and report back to a key company contact on progress; for some companies this may be a useful add-on service. Birketts is not registered as an ACSP to complete IDV, although we can supply the
Note, if a director sits on multiple company boards then it is the filing of the earliest CS01 which mandates when identity verification should take place for that director. We recommend early compliance by directors well in advance of this CS01 filing date; • Existing PSCs/RLEs will also need to be identity verified within 14/28 days respectively of an ‘appointed day’ (date yet to be announced). Newly notified PSCs/RLEs (whether on incorporation or otherwise) will also need to complete identity verification within 14/28 days Implications of failure to comply An individual who fails to complete mandatory identity verification within the correct timeframe will commit a criminal offence. Importantly, the company and each of its officers will also commit an offence if a director continues to act as a director when their identity has not been verified in the relevant timeframe. Companies are not liable for the non- compliance of their PSCs/RLEs. respectively of receiving a mandatory notification from Companies House.
“ An individual who fails to complete mandatory identity veri fi cation within the correct timeframe will commit a criminal offence
12 | September 2025
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