Further to our previous briefings, Companies House has now announced that the compulsory verification requirements for directors, members of LLPs and persons with significant control will commence on 18 November 2025. The impact of this is that as from 18 November, (and on a phased basis) certain directors, members of LLPs (and persons with significant control) will be obliged to have had their identity verified otherwise they (and the relevant company that they are appointed to) will risk committing an offence under the changes that have been implemented by the Economic Crime and Corporate Transparency Act 2023 (ECCTA).

More specifically:

In relation to directors

  • The first confirmation statement filed by an existing company after 18 November 2025 must contain the personal identification code (PIC) for each existing director.
  • Where a person is appointed as a director for the first time, either to an existing company or on a new company formation after 18 November 2025, their PIC will need to be provided on the relevant appointment or incorporation form. The appointment (and/or formation) will otherwise not be able to proceed.

In relation to Persons with Significant Control (PSC)

  • Any person who is registered as a PSC and who is also a director must file their PIC via a separate service within 14 days of the date for filing the first company's confirmation statement due after 18 November 2025.
  • Anyone already registered as a PSC but who is not a director must file their PIC via the separate service within 14 days of the start of the month in which they were born. For example, if their date of birth is 22 January, the 14 day period will begin on 1 January 2026.
  • If a person becomes a PSC after 18 November 2025, they will need to provide their PIC within 14 days of being added to the Companies House register.

In relation to LLPs

  • The first confirmation statement filed by an LLP after 18 November 2025 must contain the PIC for each existing member.
  • Where a person is appointed as a member after 18 November 2025, either to an existing LLP or on a new formation, their PIC will need to be provided on the relevant appointment or incorporation form.
  • The position with regard to PSCs of LLPs is as stated above in relation to companies.

Failure to comply

  • If a person fails to verify their identity and continues to act as a director, member of an LLP or PSC, they are committing an offence which is punishable by a fine (although the director’s appointment and any actions undertaken as a director will still be valid). A company will also commit a criminal offence if it allows a director to act while unverified.

The verification requirements relating to relevant legal entities, corporate directors, corporate members of LLPs, limited partnerships and people filing documents will take effect at a later date.

Details on how to carry out verification were included in our earlier briefing "Understanding ECCTA: Identity verification". Essentially it can be done either directly via the GOV.UK One Login service or using an authorised corporate service provider (ACSP). Gowling WLG (UK) LLP is not offering verification services, but there are ACSPs we can recommend to help with verification if assistance is required.

Next steps

  • Be clear on when the next confirmation statement for your organisation is due after 18 November 2025. For groups with a number of UK entities, establish the confirmation filing dates for each one.
  • Compile a list of directors/members and PSC who need to verify their identity, brief them on the requirements, and ask them to ensure the necessary verification is done well in advance of the relevant deadline.
  • The directors/members will need to provide their PIC to the person within the organisation (or the external organisation which files on its behalf) who is responsible for Companies House filings. The confirmation statement cannot be filed without the PICs.
  • Although PSCs are required to file their PIC independently (it is not a responsibility of the company/LLP) this can still be managed by the organisation concerned as part of its compliance process (and we expect that to be the case in practice).
  • Update your onboarding processes to make sure any new directors have verified their identity before appointment and are aware of the need to provide the PIC.

If you would like to discuss these changes and how they will impact your business, please contact Sharon Ayres, Caroline Williams or your usual Gowling WLG contact.