The Economic Crime and Corporate Transparency Act 2023 brings about some of the most significant changes to Companies House since it was established, giving it the tools to play an expanded role in tackling economic crime.  

One of the biggest changes being introduced is identity verification for all directors, people with significant control (PSCs) and those who file on behalf of companies. Companies House has recently updated its outline transition plan giving a good indication of when identity verification is likely to come into effect – both on a voluntary and mandatory basis.

Identity verification – timescales

Indicative timescales set out in the plan are:

  • From 25 March 2025 Companies House should be able to allow individuals to voluntarily verify their identity.
  • By autumn 2025 Companies House should be able to:
    • make identity verification a mandatory part of incorporation and new appointments for new directors and PSCs; and
    • as part of the annual confirmation statement filing by companies, begin the 12-month transition phase to carry out the mandatory verification of the identity of existing directors and PSCs registered at Companies House (apparently there are more than 7 million). 
  • By spring 2026 Companies House should be able to make identity verification of those filing documents on behalf of companies mandatory.
  • By the end of 2026 Companies House should be able to complete the transition period for mandatory identity verification and start compliance activity against individuals who have failed to verify their identity.

Identity verification – process

What will identity verification involve? Companies House has recently published its Registrar’s Rules relating to identity verification. These set out the requirements and routes to verification and will be supplemented by guidance (yet to be published). 

There will be three options for verifying identity directly with Companies House:

  • an app, the GOV.UK One Login Check App – this will require a smartphone with camera; 
  • the web, the GOV.UK One Login web channel; or
  • a face-to-face option, the GOV.UK One Login face to face channel – this will require a visit to a post office.

All three options will require individuals to:

  • have access to the internet;
  • provide a suitable email address and their home address (including previous addresses if less than 12 months in current address);
  • be a registered user of Companies House Services;
  • provide the required evidence to support their application for identity verification; and
  • answer any additional questions required to support their application.

The Registrar’s Rules include a detailed table of acceptable evidence required to support an application for identity verification. The specifics will vary depending on which of the routes is used, but acceptable evidence potentially includes a passport, a UK/EU photocard driving licence, a UK residency permit, a UK bank account plus UK national insurance number, or an EEA national identity photocard. 

It may also be possible to use an Authorised Corporate Service Provider (ACSP) to help with the identity verification process. ACSPs will be professional intermediaries who must be supervised within the UK by one of the relevant anti-money laundering supervisory bodies. Some ACSPs may offer identity verification services. 

Other reforms

The outline transition plan also summarises:

  • Changes already in place, such as the significantly enhanced powers of Companies House since 4 March 2024 to improve the reliability and accuracy of information on the register (see my earlier post on this).
  • Further changes relating to Companies House enforcement, investigative and data sharing powers.
  • Other related changes yet to be implemented, including the plans for accounts reform and restrictions on corporate directors – no indications of timescales are yet given for these. 

Companies House has a dedicated web page giving a useful overview of the upcoming changes, Changes to UK company law.

We will keep you posted on the implementation of identity verification and other reforms being introduced by the Economic Crime and Corporate Transparency Act 2023 over the coming months.