Verified or Blocked: The Companies House Identity Checklist UK Directors Need in 2026
Photo: Daemon1, CC0, via Wikimedia Commons
It is tempting to treat identity verification as one more Companies House chore. That reading is now out of date. Since the transition window for existing directors closed on 18 November 2025, the registrar has been able to treat an unverified individual as a practical obstacle to filing rather than a loose end to be tidied up later.
For owner-managed businesses the exposure is rarely fraud. It is drift: the director who has held office for fifteen years, the formation agent who has always filed on the company's behalf, the personal code saved on a phone that has since been replaced. None of these issues announces itself until it collides with a director appointment, a charge registration or a bank mandate review.
Who is caught by the regime
Verification was introduced under the Economic Crime and Corporate Transparency Act 2023 and applies to individuals, not companies. In an owner-managed group the same person is often caught several times over: as a director here, a person with significant control (PSC) there, a designated member of an LLP elsewhere. A single verified identity covers every appointment, so the burden is front-loaded rather than repeated.
Those in scope include company directors, LLP members, general partners in limited partnerships and PSCs. Where a PSC is a corporate entity — a registerable relevant legal entity — the entity itself does not verify, but the individual who confirms its details must.
Two misconceptions are worth dispelling early. First, company secretaries are not within scope. Second, verification confirms who you are; it does not authorise you to file. It is an identity check, not a permission slip.
Two routes, one portable identity
There are two ways to satisfy the requirement. The first is direct, through a GOV.UK One Login account using a biometric passport or photocard driving licence and a short liveness check. The second is through an Authorised Corporate Service Provider (ACSP) — typically an accountant, solicitor or formation agent supervised under the money laundering regime and registered with Companies House — who carries out checks to the same standard.
Either route produces a personal code: a short alphanumeric string that links a verified identity to filings. It should be handled like a password. It should not be emailed to an agent, pasted into a group chat or left on a shared drive. A professional firm will have a controlled process for receiving it; an agent who asks for it by text message deserves a second look.
What unverified status actually blocks
This is where the consequences bite. Companies House can reject filings that depend on an unverified identity, and an individual who has not verified cannot be validly appointed as a director. Persistent non-compliance is not merely inconvenient: failing to verify without reasonable excuse is a criminal offence, and the registrar has a financial penalty regime available, alongside prosecution in serious cases.
The commercial knock-on effects are quieter but frequently more expensive. Banks, lenders, payment providers and counterparties increasingly read the register as a live compliance signal. A mandate review, a new facility or an insurer's due diligence pack can stall while a director's status is resolved — and because this reflects market practice rather than any statutory requirement, it is hard to predict and easy to overlook.
The traps we see most often
Name mismatch. Verification must line up with the register. A passport in a married name, a middle name omitted at incorporation or a shortened forename will all cause friction. Resolve discrepancies deliberately rather than assuming the system will reconcile them.
The agent assumption. Instructing a third party does not discharge a director's own obligation. If the agent is not a registered ACSP, the filing may be refused however well drafted it is.
The corporate PSC. Where shares are held through a holding company or a trustee arrangement, the individual confirming the entity's details must still verify, and the ownership chain should be documented before anyone is asked to sign a confirmation statement.
Dormant and semi-dormant companies. There is no exemption for companies that file little or nothing.
Succession lag. A new director cannot be appointed first and verified later. Build verification into the completion timetable for any group reorganisation or sale, and consider interim signing arrangements.
A director's checklist before the next filing
- Pull the register for every company and LLP in the group and list each individual appointment.
- Match each name exactly to the identity document you intend to use.
- Confirm which appointments remain live, and resign from any that do not.
- Verify through GOV.UK One Login, or through an ACSP you have checked on the Companies House register.
- Store the personal code in a password manager and record who else has access.
- Confirm in writing with any filing agent that they are acting as an ACSP for your documents.
- Tell your bank and any lender of your verified status where they have asked for evidence during onboarding or review.
- Minute the board's review, so the position is documented at the next funding round, refinancing or sale.
The bottom line
Identity verification is unglamorous, inexpensive and easy to postpone. That is precisely why it causes problems. A short audit now is a good deal cheaper than a rejected filing at a completion deadline — or an awkward question from a lender about why a director of eight years is still unverified.