Companies House identity checks: what every director must do now

There is a quiet piece of admin sitting in the diary of almost every company in the country, and it has a hard edge to it. Since 18 November 2025, verifying your identity with Companies House has been a legal requirement rather than a nice idea. For existing directors, the moment of truth arrives with your company’s next confirmation statement — which means most companies meet it at some point in the twelve months to 18 November 2026.

It sounds like paperwork. In practice, it is the sort of thing that can stop a company filing, hold up a sale, delay a refinance, or leave a family unable to keep a business running smoothly at exactly the wrong moment. That last point is why we are writing about it at all.

What the rule actually is

Under the Economic Crime and Corporate Transparency Act, Companies House now has to know who is really behind a company. From 18 November 2025 identity verification became compulsory for directors and for people with significant control.

The mechanics are simple enough:

• Each individual verifies once, as a person — not once per company.
• On verifying, you are issued a Companies House personal code. It belongs to you and you keep it.
• Existing directors must confirm they have verified, and provide that personal code, at the same time as the company files its next confirmation statement after 18 November 2025.
• The company cannot file its confirmation statement until every one of its directors is verified.
• People with significant control have their own timetable — a 14-day window in which to provide their personal code and verification statement, running from a date that depends on their circumstances.

New appointments are caught immediately, and continuing to act as a director after your deadline without complying is an offence, exposing the individual and the company to financial penalties. Companies House can also mark the public record to show a director has not verified — which is not the note you want a lender or a buyer reading.

How you actually verify

There are two routes. You can verify directly with Companies House using GOV.UK One Login, with photo identification — a passport or a UK driving licence — either through the app or in person at a Post Office. Or you can verify through an Authorised Corporate Service Provider: an accountant, solicitor or company formation agent registered with Companies House to carry out these checks. Either way, the output is the same personal code.

A worked example

Take a Worthing couple — call them Ray and Denise, purely as an illustration. They run a plant hire company built up over twenty-two years. Ray is managing director, Denise is a director and handles the books, and their daughter Kate was appointed a director four years ago so that the next generation had a foot in the door. Ray’s brother Terry holds a quarter of the shares from the early days and has not been to a meeting since 2019.

The confirmation statement is due in the spring. Denise verifies in an evening, on her phone. Ray gets there after a bit of grumbling about the app. Kate, who is on maternity leave and not thinking about Companies House, has not. Terry, as a person with significant control, has his own 14-day window and has not opened the letter.

So the filing sits there. The statement cannot go in until Kate is verified. Terry’s window ticks along without him. Meanwhile the bank has asked for up-to-date filings as part of a refinance on the yard, and the buyer of a small competitor wants clean records before exchanging.

None of that is a scandal. It is simply four adults with different diaries — which is exactly how these deadlines get missed.

The traps

The quiet director. Every family company has one: a spouse, a parent, an adult child appointed years ago for a good reason and rarely troubled since. They still need a personal code. So does the director who has retired in all but name and never resigned formally.

Assuming the accountant has it covered. Your accountant can file, and if they are an Authorised Corporate Service Provider they can verify you. What they cannot do is verify a person who will not sit down with their passport. Identity verification is personal to the individual.

Confusing the two timetables. Directors are tied to the confirmation statement. People with significant control have a separate 14-day window. A shareholder who is not a director can easily assume none of this applies to them.

Dormant and holding companies. A dormant company still files a confirmation statement, so its directors still need to be verified. Property investors with a company per building, or a holding company above two trading businesses, may have the same handful of people to verify across several filings.

Capacity and absence. This is the trap that concerns us most. If a director is seriously ill, abroad, or has lost mental capacity, they cannot verify. A company that needs that person’s code to file has a problem no amount of goodwill solves quickly. If a sole director dies, there may be nobody able to act at all until the shares pass and a new director is appointed.

Where this meets your estate planning

Identity verification has turned a soft risk into a hard one. Until now, a director who was unwell or unreachable was an inconvenience. Now the company’s ability to file — and to look creditworthy on the public record — can depend on one person being able to prove who they are.

That makes two long-standing questions more urgent than they were. First: if you could not act tomorrow, who could act for you in your business? Second: if you died, who controls your shares, how quickly, and are they willing and able to be a director? Sole directors and sole shareholders should look hardest here, because the answer is often “nobody, for several months”.

Business Relief sits behind all of this. From April 2026 there is a £2.5m combined cap on the value qualifying for full Business Relief and Agricultural Property Relief, with 50% relief above it. A trading company that cannot file, cannot show clean records, or cannot appoint a decision-maker is a business whose value and even its trading status can drift — and that is a tax question as much as a tidiness one. If a sale is in view, the Business Asset Disposal Relief lifetime limit of £1m is worth knowing about before you negotiate rather than after.

What to do

• List every company you are involved with, including dormant ones, and every director and person with significant control in each.
• Check your next confirmation statement date on the Companies House register. That is your directors’ deadline.
• Get your personal code now, via GOV.UK One Login or an authorised agent, and do not wait for the filing month.
• Collect the codes centrally — from the quiet directors first, because they will take longest.
• Tidy the board. If someone has not been a real director for years, deal with it properly now rather than at deadline.
• Ask the harder question: who can act for you, in the business, if you cannot — and does the paperwork say so.

A note for property investors

If you hold buildings through companies, the arithmetic gets larger quickly. Four properties in four special purpose vehicles, with you and your spouse as directors of each, is four confirmation statements — and each of them is blocked until both of you are verified. The good news is that you verify once and reuse the same personal code across every appointment. The less good news is that four filing dates spread through the year gives you four chances to be caught out, and lenders on buy-to-let portfolios increasingly look at whether filings are current before they release funds.

It is also worth remembering that a company structure was probably chosen for tax or for financing, not for what happens on a bad day. Shares in a property company do not usually qualify for Business Relief, so the ordinary inheritance tax rules apply: the nil-rate band of £325,000, frozen to 2030, and the residence nil-rate band of £175,000, which tapers where the estate exceeds £2m. A couple can reach up to £1m combined in the right circumstances. Directors’ verification is the prompt; the structure is the real conversation.

In short

Verification itself takes most people a single evening. The work is in the coordination — finding the four or five people whose codes you need and getting each of them to spend that evening. Start it well before the filing month and it is a non-event. Leave it and you are chasing a relative’s passport photo while a lender waits.

If your company’s future depends on a small number of people being able to act, it is worth an hour of proper thought about what happens when one of them cannot. A Discovery Call is 30 minutes, the fee is £30, and it is credited against our fees if you go on to instruct us — a straightforward way to look at your business, your shares and your Will as one picture rather than three.